JUDGMENT

S.H. Kapadia, J. —

1. Heard learned counsel on both sides.

2. In this batch of civil appeals, the narrow issue which arises for determination is the nature of the loss suffered by the appellant(s) [assessee(s)] - whether Rs.2,43,750/- was a short-term capital loss, as contended on behalf of the assessee(s), or whether the said loss was a long-term loss, as contended on behalf of the Revenue?

3. In the lead matter, being Civil Appeal No.634 of 2006, we are concerned with Assessment Year 1992-1993 corresponding to the Financial Year ending 31st March, 1992.

4. The assessee was a shareholder in Jindal Iron and Steel Company Limited [‘JISCO’, for short]. The said Company announced in January, 1992, issue of 12.5% equity secured PCDs [Partly Convertible Debentures] of Rs.110/- for cash at par to shareholders on Rights Basis and employees on Equitable Basis. The Issue opened for subscription on 14th February, 1992, and closed on 12th March, 1992. As the assessee held 1500 equity shares of JISCO, assessee received an offer to subscribe to 1875 PCDs of JISCO on Rights Basis. Assessee renounced his right to subscribe to PCDs in favour of Colorado Trading Company on 15th February,