https://www.taxtmi.com/caselaws?id=19196 Ownership in shares passed only in accordance with the parties' intended staged transfer arrangement, not merely because an irrevocable guarantee was given and the share certificates and transfer forms were held by the guarantor. The agreement linked transfer to instalment payments and reserved the vendors' right to receive dividend until full payment, so the remaining four-fifths of the shares did not pass to the purchasers during the relevant year. On that basis, dividend attributable to the untransferred shares remained referable to the vendors and was not taxable in the hands of the purchasers. en-us Fri, 11 Jun 1993 00:00:00 +0530 Wed, 04 Nov 2009 15:56:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19196 Ownership in shares passed only in accordance with the parties' intended staged transfer arrangement, not merely because an irrevocable guarantee was given and the share certificates and transfer forms were held by the guarantor. The agreement linked transfer to instalment payments and reserved the vendors' right to receive dividend until full payment, so the remaining four-fifths of the shares did not pass to the purchasers during the relevant year. On that basis, dividend attributable to the untransferred shares remained referable to the vendors and was not taxable in the hands of the purchasers. Case-Laws Income Tax Fri, 11 Jun 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19196