Transfer of share completes when the share certificate along with duly executed transfer deed is handed over to the transferee

RELEVANT PARAGRAPH 9. We have considered the rival submissions and perused the record of the case. The facts as noted earlier in detail in the arguments of Ld Counsel for the assessee are not disputed. Admittedly, it is a case of sale of shares. In this regard, share purchase agreement was entered into on 27.1.2005 and final delivery of shares took place on 1/15.4.2005. In the share purchase agreement, detailed provisions were made restricting the vendors from exercising various rights in relation to shares. Revenues’ main contention is that on account of substantial extinguishment of r...