HC held contribution of Land by partner to Firm as SHAM transaction

CIT Vs M/s Carlton Hotel Pvt Ltd. (Allahabad High Court) Conclusion: The entire consideration for free-hold land was paid by M/s SICCL but in what capacity, was not known and transfer of same land by assessee to SICCPL at a consideration which had a vast difference than that was acquired by assessee after execution of free-hold deed did not conform to even any normal business transaction entered into by a person of ordinary prudence, and, therefore, there existed all the facts and circumstances to show prima facie that entire transaction of contribution to partnership firm of assessee and SICC...