1990 (7) TMI 90

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.... this application under section 26(3) of the Gift-tax Act, 1958, the applicant is asking this court to refer the following questions for the opinion of this court : "(1) Whether, in law and the circumstances of the case, the Income-tax Appellate Tribunal was justified in holding that no deemed gift is involved and accordingly no gift-tax was chargeable in this case ? (2) Whether, in law and ....

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...., 1973, the income of the firm for the period January 1, 1972, to November 24, 1972, was separately shown, according to which the income of the firm was determined at Rs. 6,88,375. The partners of the firm who became shareholders of the company were allotted shares of the face value of Rs. 8,00,000. The Income-tax Officer held that the shares allotted were in lieu of capital contributed by the ....