1984 (7) TMI 200

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....ed on the widow, the sons and the daughters, in the proportions laid down under the Mohammedan Inheritance law. The sons and the daughters formed a Private Limited Co. Called "Nazeeria Traders Pvt. Ltd. and contributed the assets acquired by their inheritance in lieu of the shares from the company. The route permits of the passenger buses were also transferred by the Andhra Pradesh Government from the name of late Mahboob Khan to the name of the company. The company operated the buses upto 31st March 1967. In the previous year ended 31st March, 1968 the company sold 22 buses with route permits to the three daughters of the later Mahboob Khan. The transfer was made at the written down value appearing in the books of the assessee. 2. In th....

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....sure, then the element of gift involved in the transactions of the assessee with the three daughters of late Mahboob Khjan would be as much at Rs. 5,37 lakhs. it is also pointed out that the company had in the course of IT proceedings furnished a computation of the probable maximum fair market value of Rs. 5,82.,000 in respect of these 22 buses taking this into account it is contended that the Commissioner (A) should have confirmed the gift at the figure of Rs. 1,25,000. 5. On behalf of the assessee, reliance is placed on the order of the Commissioner (A) it is pointed out that the assessee had given three workings in respect of the value of the gift, element and it was only in the course of such discussion and in the light of such calcu....