Exp. couldn't be treated as incurred towards transfer of shares just because it was required to be paid as per SPA

INCOME TAX : Where as per share purchase agreement, shares of a company were sold by all its shareholders to another company, sum paid by shareholders to a trust proposed to be set up for benefit of ex-employees of seller company was to be regarded as voluntary payment; same was not allowable as expenditure incurred wholly and exclusively for transfer of shares

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