https://www.taxtmi.com/caselaws?id=37049 Section 44E of the Indian Income-tax Act, 1922 applied only where the owner of securities agreed to sell or transfer them and, by the same or a collateral arrangement, agreed to buy them back, or had an option to re-acquire them, so that income from the securities became receivable otherwise than by the owner. On the facts stated, the employees held the shares on their own account, and there was no agreement or option in favour of the assessee to repurchase or re-acquire them. A mere understanding that the assessee would purchase the shares if the holders wished to sell did not satisfy the statutory condition, and section 44E was therefore not attracted. en-us Fri, 30 Jun 1978 00:00:00 +0530 Fri, 26 Mar 2010 11:26:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37049 Section 44E of the Indian Income-tax Act, 1922 applied only where the owner of securities agreed to sell or transfer them and, by the same or a collateral arrangement, agreed to buy them back, or had an option to re-acquire them, so that income from the securities became receivable otherwise than by the owner. On the facts stated, the employees held the shares on their own account, and there was no agreement or option in favour of the assessee to repurchase or re-acquire them. A mere understanding that the assessee would purchase the shares if the holders wished to sell did not satisfy the statutory condition, and section 44E was therefore not attracted. Case-Laws Income Tax Fri, 30 Jun 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37049