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    <title>2025 (3) TMI 2058 - ITAT DELHI</title>
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    <description>Taxable income arising from an alleged difference between the sale price and market price of shares must be assessed in the hands of the person shown to hold title to those shares. The notes state that the assessment and appellate orders did not explain how the assessee acquired title to the shares allegedly sold. Determination of ownership was therefore necessary before any addition could be sustained. The addition was not finally sustained, and the matter was restored to the first appellate authority for fresh adjudication after examining title and relevant additional evidence in accordance with law.</description>
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      <link>https://www.taxtmi.com/caselaws?id=470304</link>
      <description>Taxable income arising from an alleged difference between the sale price and market price of shares must be assessed in the hands of the person shown to hold title to those shares. The notes state that the assessment and appellate orders did not explain how the assessee acquired title to the shares allegedly sold. Determination of ownership was therefore necessary before any addition could be sustained. The addition was not finally sustained, and the matter was restored to the first appellate authority for fresh adjudication after examining title and relevant additional evidence in accordance with law.</description>
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