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    <title>2022 (5) TMI 683 - ITAT AHMEDABAD</title>
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    <description>The Department&#039;s appeal was dismissed, while the assessee&#039;s appeal was partly allowed, granting relief for proportionate allotment of shares and shares received due to renouncement by relatives. The reassessment proceedings were upheld, with the Tribunal applying section 56(2)(vii)(c) to shares received from third-party renouncement. The valuation of shares at Rs. 205.55 per share was upheld. The issues of levy of interest under section 234 and initiation of penalty proceedings under section 271(1)(c) were not addressed by the Tribunal as they were not pressed by the assessee.</description>
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      <description>The Department&#039;s appeal was dismissed, while the assessee&#039;s appeal was partly allowed, granting relief for proportionate allotment of shares and shares received due to renouncement by relatives. The reassessment proceedings were upheld, with the Tribunal applying section 56(2)(vii)(c) to shares received from third-party renouncement. The valuation of shares at Rs. 205.55 per share was upheld. The issues of levy of interest under section 234 and initiation of penalty proceedings under section 271(1)(c) were not addressed by the Tribunal as they were not pressed by the assessee.</description>
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