CL : Shares of a company are a separate asset wholly distinct from assets held by company. Thus where there was dilution of share capital of parent company TGC as well as transfer of shares held by TGC in petitioner company, transfer of shares of petitioner company could not be construed as transfer of assets of petitioner company. Thus, fundamental premise that there had been a transfer of subject property is erroneous and consequently, demand of unearned increase founded on same
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