JUDGMENT - DEVADHAR J.P., J.:---This Tax Appeal is filed by the appellant/assessee under section 260-A of Income Tax Act, 1961 relating to Assessment Year 86-87.

2.According to the assessee, the following substantial questions of law do arise out of the order of the Tribunal. They are:

(1) Whether in determining the capital gains chargeable to tax can the Assessing Officer have regard to a so called notional benefit in determining the full value of the consideration that accrues or arises as a result of the transfer?

(2) Whether capital gains would be chargeable only on the full value of the monetary consideration accruing or arising to an assessee and whether any incidental or remote benefit which benefit does not flow directly to the appellant is to be ignored in determining the chargeability to tax of the capital gains?

(3) Whether on the facts and in the circumstances the Tribunal was justified in holding that the full value of the consideration accruing to the appellant on the transfer of the shares of Piramal Rasayan Limited would be Rs. 16,23,000/- and not rupee 1/- which was the amount that the appellant received as a result of the transfer:

(4) Whether the Tribunal having foun

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