https://www.taxtmi.com/caselaws?id=36632 The statutory presumption of an ulterior motive under section 269C(2)(b) is not displaced merely because the revenue did not take separate assessment action against the transferor or transferee. Acquisition proceedings and assessment proceedings operate in different fields, and inaction in assessment may be a relevant circumstance only when read with other material; it does not by itself establish bona fides or negate the presumption based on the apparent consideration and fair market value difference. The Tribunal erred in treating such inaction as sufficient to set aside the acquisition. en-us Wed, 26 Dec 1979 00:00:00 +0530 Tue, 23 Mar 2010 15:39:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36632 The statutory presumption of an ulterior motive under section 269C(2)(b) is not displaced merely because the revenue did not take separate assessment action against the transferor or transferee. Acquisition proceedings and assessment proceedings operate in different fields, and inaction in assessment may be a relevant circumstance only when read with other material; it does not by itself establish bona fides or negate the presumption based on the apparent consideration and fair market value difference. The Tribunal erred in treating such inaction as sufficient to set aside the acquisition. Case-Laws Income Tax Wed, 26 Dec 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36632