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 per share and the ex- rights price per share) based on an earlier Supreme Court decision in case of Miss Dh...