(1.) HEARD Sri D.D. Chopra, learned standing counsel appearing on behalf of IT Department.
(2.) THIS is an appeal under the GT Act (hereinafter referred to as "the Act"). Following substantial questions of law have been involved :
(3.) THE brief facts of the case are that the AO has framed the assessment under s. 16(1)/15(3) of the GT Act (hereinafter 11,972 shares to various companies. The AO found that the company had sold shares on the face value of Rs. 100 each and he was of the view that the shares in question had been transferred at a value less than the fair market value. The AO recorded the reasons for initiation of proceedings under s. 16(1) of the Gift Act as follows :