Gift of Shares to NDAW Subject to Gift Tax Under Exclusion Clause of Section 47(XIV) of Income Tax Act.

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....Gifts made - the assessee was absolute owner of NDAW upto 24/07/2007 and transferred his 51% shares to RBE and then made the gift to NDAW, in which he still holds 49% stakes, thus, the transfer is covered by exclusion clause u/s 47(XIV) of the Act, consequently, is liable to Gift Tax - AT....