Court Rules Transferor Not Taxed for Share Losses u/s 147; Liability Falls on Recipients Per Amendments.

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....Reopening of assessment u/s 147 - loss on transactions of sale and purchase of shares - even otherwise the assessee being transferor of shares cannot be subjected to tax in the instant case, more particularly, considering the amendment brought by the Legislation on the statute book in the form of Sections 50CA and 56(2)(x)of the Act, which is applicable with effect from 01.04.2018 and 01.04.2017 respectively. The conjoint reading of both sections, clearly provides that the tax liability if any, arise in such kind of transactions will be applicable in the hands of recipients and no liability can be imposed on the transferor of shares. - HC....