VATSALA SHENOY vs. JT.COMMISSIONER OF INCOME TAX
C.A. No.-001234-001234 - 2012Supreme Court18 Oct 2016
Section 260Section 583(4)(a)
section contemplates that any surplus
accruing on transfer of capital assets is chargeable to tax
in the previous year in which transfer took place. In this
case, transfer took place on July 18, 1969. The second
test which needs to be applied is the test of
allocation/attribution. This test is spelt out in the judgment
of this Court in Mugneeram
