https://www.taxtmi.com/caselaws?id=13555 Reopening of gift-tax proceedings requires objective material supporting a bona fide reason to believe that taxable gifts escaped assessment, rather than a mere change of opinion; later search material and appraisal records may support initiation. Transfers of shares for inadequate consideration may constitute deemed gifts where their commercial substance indicates tax avoidance and the claimed subsidiary relationship lacks genuine statutory or commercial basis. Valuation of listed shares subject to a lock-in restriction must reflect their actual non-transferability and lack of marketability, rather than ordinary quoted-share treatment. Interest on gift-tax is confined to the statutory basis applicable to tax declared in the return and does not automatically extend to enhanced assessed tax. en-us Fri, 15 Dec 2006 00:00:00 +0530 Fri, 29 May 2009 16:48:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13555 Reopening of gift-tax proceedings requires objective material supporting a bona fide reason to believe that taxable gifts escaped assessment, rather than a mere change of opinion; later search material and appraisal records may support initiation. Transfers of shares for inadequate consideration may constitute deemed gifts where their commercial substance indicates tax avoidance and the claimed subsidiary relationship lacks genuine statutory or commercial basis. Valuation of listed shares subject to a lock-in restriction must reflect their actual non-transferability and lack of marketability, rather than ordinary quoted-share treatment. Interest on gift-tax is confined to the statutory basis applicable to tax declared in the return and does not automatically extend to enhanced assessed tax. Case-Laws Income Tax Fri, 15 Dec 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13555