Sale of CCDs to holding co. which resulted in a loss couldn't be construed as colourable device

INCOME TAX: Where assessee-company purchased Compulsory Convertible Debentures (CCDs) from its subsidiary company and sold them to its holding company which had resulted in short term capital loss, in view of fact that documentary evidences for purchase and sale of CCDs were not doubted by revenue and independent Chartered Accountant had determined fair market value of CCDs, transactions of sale of CCDs to related concern could not be construed as a colourable device to set off huge profits earn

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