https://www.taxtmi.com/caselaws?id=466574 Fresh allotment of unlisted shares at consideration below fair market value attracts taxation under the provision treating the excess of FMV over consideration as income, because the statutory language and administrative guidance encompass allotments; the addition under that provision was therefore upheld. Where transfer of shares to related parties is supported by no contemporaneous evidence and declared consideration is held not ascertainable, the deeming rule applies to treat FMV as full value for capital gains computation; that addition under the deeming provision was therefore upheld. Both additions were sustained on the facts. en-us Fri, 02 Jan 2026 00:00:00 +0530 Thu, 12 Feb 2026 19:01:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466574 Fresh allotment of unlisted shares at consideration below fair market value attracts taxation under the provision treating the excess of FMV over consideration as income, because the statutory language and administrative guidance encompass allotments; the addition under that provision was therefore upheld. Where transfer of shares to related parties is supported by no contemporaneous evidence and declared consideration is held not ascertainable, the deeming rule applies to treat FMV as full value for capital gains computation; that addition under the deeming provision was therefore upheld. Both additions were sustained on the facts. Case-Laws Income Tax Fri, 02 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466574