https://www.taxtmi.com/caselaws?id=36884 Reciprocal gifts of shares between closely connected families can be treated as indirect cross-transfers where the surrounding facts show a common scheme or circuitous arrangement. The Bombay HC principle applied here is that section 16(3) of the Indian Income-tax Act, 1922 extends beyond direct transfers to inter-connected transactions made in consideration of, or in expectation of, a reciprocal transfer. Mere differences in timing, number of shares, or identity of all donees do not necessarily break the link if the overall pattern shows mutual connection. On that basis, the share transfers to the assessee's wife and minor children were includible in the assessee's total income. en-us Tue, 08 Aug 1978 00:00:00 +0530 Thu, 25 Mar 2010 12:02:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36884 Reciprocal gifts of shares between closely connected families can be treated as indirect cross-transfers where the surrounding facts show a common scheme or circuitous arrangement. The Bombay HC principle applied here is that section 16(3) of the Indian Income-tax Act, 1922 extends beyond direct transfers to inter-connected transactions made in consideration of, or in expectation of, a reciprocal transfer. Mere differences in timing, number of shares, or identity of all donees do not necessarily break the link if the overall pattern shows mutual connection. On that basis, the share transfers to the assessee's wife and minor children were includible in the assessee's total income. Case-Laws Income Tax Tue, 08 Aug 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36884