https://www.taxtmi.com/caselaws?id=791741 A transfer of shares by a holding company to its wholly owned Indian subsidiary was treated as a bona fide transaction, not a colourable device or non-genuine arrangement. The mere presence of a tax advantage did not justify disregarding the transfer absent material showing sham, lack of commercial substance, or abuse of the statutory framework. The prior long-term investment character of the holding was accepted, and the later acquisition of the remaining shares did not convert it into stock-in-trade. The transfer before merger was viewed as commercial expediency, and the valuation objection failed because no specific defect in the methodology was shown. Section 47(iv) was held to apply, and the addition was deleted. en-us Wed, 29 Apr 2026 00:00:00 +0530 Sat, 16 May 2026 09:09:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791741 A transfer of shares by a holding company to its wholly owned Indian subsidiary was treated as a bona fide transaction, not a colourable device or non-genuine arrangement. The mere presence of a tax advantage did not justify disregarding the transfer absent material showing sham, lack of commercial substance, or abuse of the statutory framework. The prior long-term investment character of the holding was accepted, and the later acquisition of the remaining shares did not convert it into stock-in-trade. The transfer before merger was viewed as commercial expediency, and the valuation objection failed because no specific defect in the methodology was shown. Section 47(iv) was held to apply, and the addition was deleted. Case-Laws Income Tax Wed, 29 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791741