The main legal point established in the judgment is the determination of the genuineness of transactions, the concept of lifting the corporate veil, and the applicability of tax liability on transferred actionable claims.

( 1 ) THIS is an appeal under Section 260a of the Income-tax Act, 1961 (in short, the act ) filed by assessee. The dispute relates to the assessment year 1992-93. Challenge is to the order passed by the Income-tax Appellate Tribunal, Delhi Bench c , New Delhi (in short the Tribunal )

( 2 ) FACTUAL position, as highlighted by assessee, which needs to be noted is essentially as follows. Assessee is a private limited company, which derived income at the relevant point of time from exhibition of shorts/slides, hiring of news reels, rental of shops, show rooms in its film exhibition complex, rendering of various management services to a cold storage concern. Assessee also received an amount on account of disputed claims and dues in respect of its erstwhile business of civil construction works carried under several contracts. The aforesaid contracts were with M/s. Hindustan Steelworks Construction Co. Ltd. (in short, hscl ) These related to the construction of steel plant complex at Bokaro during the period from 1967 to 1984. In respect of these contracts, disputes arose between assessee and HSCL in the matter of settlement of claims for payment claimed to be due to it. The payments related to extra or additional items of work executed by assessee, which was accepted by HSCL in respect of two items, that is, in relation to contract No. LI/ce/6 and GM/386/ 75 dated 27. 06. 1967 and 25. 04. 1975 respectively. The contracts were completed in 1973 and 1978 respectively. Similarly, contract No. GM/469/78 and contract No. CM/ 486/79 were closed in May, 1981. HSCL refused permission to the assessee to remove its constructional machinery and equipments from the work sites and also issued notices to the effect that the additional work would be carried out by HSCL at the risk and expenses of assessee. A substantial part of claims of assessee related to four contracts referred to above. There was exchange of correspondence between the parties in regard to the settlement to be arrived at Awaiting settlement and outcome of negotiations, the Board of Directors of assessee transferred the actionable claims against HSCL in respect of aforesaid four contracts to another company, namely, M/s. Bhagat Papers Ltd. (in short, BPL) The transfer was made for a sum of Rs. 50,000. 00 subject to the liabilities and equities attached to assessee in respect of aforesaid four contracts and bearing of expenses of the litigation. This was done on the basis of an instrument of transfer dated 14. 12. 1981. After some point of time, BPL transferred the aforesaid actionable claims to another company, namely, M/s. D. R. Bhagat Brothers Ltd. (in short, DRB ). This was purportedly on the basis of a resolution dated 12. 10. 1982 of the Board of Directors of BPL. The aforesaid transfer was made by a tripartite arrangement dated 12. 10. 1982 between assessee, BPL and DRB. On 10. 03. 1987, DRB acquired 51% of equity shares capital of M/s. Maya Enterprises Pvt. Ltd. (in short, MEP ). The said company was converted into a public company limited, named as M/s. Maya Enterprises Ltd. (MEL ). On 13. 04. 1987, DRB authorised the assignment of actionable claims by way of a gift to MEL. This was in terms of a special resolution dated 30. 04. 1987. In 1988, HSCL filed a Money Suit bearing No. 2 of 1988 against the assessee in the Court of the Sub-Judge of Chas. This was in respect of six contracts being the four noted above, the other contracts being contract No. MD/650-VI/74-3782 and contract No. GM/485/79. Assessee made a counter claim for an amount of Rs. 3. 32 crores. Subsequently, disputes between the parties in respect of these contracts were referred to arbitration and were the subject matter of nine proceedings before various arbitrators. On 04. 01. 1990, the Patna High Court passed an order on the application of assessee staying the proceedings in Suit and allowed time of four months for completion of various proceedings before the arbitrators. On 30. 04. 1990