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1982 (6) TMI 44 - HC - Income TaxExtract: ....... case, hitherto not pleaded, that the donation, though ex facie of shares, was in substance of cash. For the above reasons, both the questions formulated by the Tribunal for our opinion reproduced earlier are answered in the negative, that is, against the assessee and in favour of the Revenue and the reference is disposed of accordingly with costs.
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