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    <title>2020 (12) TMI 731 - ITAT DELHI</title>
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    <description>A corporate donor&#039;s gift of shares held as stock in trade to group companies, made pursuant to family realignment and authorised by its constitution and approvals, did not give rise to taxable business income because no money or other consideration was received and no charging provision covered the notional market value of the gifted stock. Applying the real income principle and the reasoning in Kikabhai Premchand, the transfer was not assessable as business income. The rejection of books under section 145 also failed because it rested on the same unsupported assumption of suppressed sale proceeds; the accounts reflected the gift and related reserve entries, and no independent defect justified rejection.</description>
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    <pubDate>Fri, 18 Dec 2020 00:00:00 +0530</pubDate>
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      <title>2020 (12) TMI 731 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=401932</link>
      <description>A corporate donor&#039;s gift of shares held as stock in trade to group companies, made pursuant to family realignment and authorised by its constitution and approvals, did not give rise to taxable business income because no money or other consideration was received and no charging provision covered the notional market value of the gifted stock. Applying the real income principle and the reasoning in Kikabhai Premchand, the transfer was not assessable as business income. The rejection of books under section 145 also failed because it rested on the same unsupported assumption of suppressed sale proceeds; the accounts reflected the gift and related reserve entries, and no independent defect justified rejection.</description>
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      <pubDate>Fri, 18 Dec 2020 00:00:00 +0530</pubDate>
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