(1.) AT the instance of the Additional Commissioner of Gift-tax, Madras-I, the Income-tax Appellate Tribunal, Cochin Bench, under Section 26(1) of the Gift-tax Act, has referred the following two questions for the opinion of this court:
(2.) THE assessee is a partnership firm consisting of two partners, Veerappa Chettiar and Chinnan Chettiar. THE partnership firm owned 520 shares in the Chettinad Mercantile Bank Ltd. THE original cost of acquisition of these shares was Rs. 60 per share. THE assessee-firm sold these shares to the following persons at the prices noted against each one of them : <FRM>JUDGEMENT_429_ITR110_1977Html1.htm</FRM>
(3.) AS far as the second question is concerned, Section 4(1)(a) of the Act states :