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    <title>1951 (6) TMI 21 - HIGH COURT OF PUNJAB AND HARYANA</title>
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    <description>A gratuitous transfer of shares that formed part of a scheme reducing excess profits tax liability was treated as falling within the anti-avoidance power under section 10A of the Excess Profits Tax Act, 1940, because material existed to support the officer&#039;s opinion that the main purpose was tax avoidance or reduction. The opinion itself was not open to challenge under section 66 of the Income-tax Act. The Tribunal was also entitled to disregard an earlier administrative finding, since it was based on different facts and was not shown to be binding or to operate as res judicata. Both issues were decided against the assessee and in favour of the Revenue.</description>
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    <pubDate>Mon, 04 Jun 1951 00:00:00 +0530</pubDate>
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      <title>1951 (6) TMI 21 - HIGH COURT OF PUNJAB AND HARYANA</title>
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      <description>A gratuitous transfer of shares that formed part of a scheme reducing excess profits tax liability was treated as falling within the anti-avoidance power under section 10A of the Excess Profits Tax Act, 1940, because material existed to support the officer&#039;s opinion that the main purpose was tax avoidance or reduction. The opinion itself was not open to challenge under section 66 of the Income-tax Act. The Tribunal was also entitled to disregard an earlier administrative finding, since it was based on different facts and was not shown to be binding or to operate as res judicata. Both issues were decided against the assessee and in favour of the Revenue.</description>
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