R JAGADISH CHANDRAN IND Vs. INSPECTING ASST COMMISSIONER OF INCOME TAX
INCOME TAX APPELLATE TRIBUNAL
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S. Kannan, Accountant Member -
(1.) THESE three appeals, which give rise to a single common issue, were heard together, on being referred to this Special Bench of the Income-tax Appellate Tribunal, Madras Bench "D", see pro forma dated June 27, 1990, for making reference by a Bench to the President, Income-tax Appellate Tribunal, under Section 255(3) of the Income-tax Act, 1961, for constitution of a Special Bench, and the President's orders thereon.
(2.) The assessee first mentioned in the cause title is assessed to tax in the status of an individual. The second assessee is a specified Hindu undivided family, of which the said R. Jagadish Chandran is the karta. The assessee mentioned last in the cause title is assessed to tax in the status of an individual.
The assessment year involved is common, namely, assessment year 1982-83. The relevant previous year is also identical, namely, the year of accounting ending on June 30, 1981.
(3.) SMT. R. Vijayalakshmi, the mother of Jagadish Chandran (individual), had acquired prior to January 1, 1964, 1,000 equity shares (of the face value of Rs. 100 each) in Premier Mills Ltd. During 1965 and 1966, she purchased 160 equity shares of the same company. In 1967, she received bonus shares in the ratio of 1:1, which augmented her holdings to 2,320 shares. In 1967, she purchased 30 shares, thus increasing the entire holdings to 2,350 shares. There were further issues of bonus shares in 1975 and 1977.;
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