Right to subscribe the additional shares arises on the date when the company decides to come out with the right offer

Background

• The assessee held certain number of equity shares in a listed Indian Company and the company issued equity secured partly convertible debentures (PCDs) for cash at par to its shareholders on right basis.
• The assessee received an offer to subscribe such PCDs on right basis which he renounced in favor of a buyer against a consideration.
• The assessee claimed loss on account of diminution in the value of his original equity shares (being the difference between the cum-right price

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