Per Shri M.A. Ajinkya, Accountant Member - This is an appeal by the assessee against the appellate order of the CIT (Appeals)-VI dated 14-1-1986 for the assessment year 1983-84.

2. The appellant herein is a foreign non-resident company. We are concerned with its appeal for the assessment year 1983-84, for which the accounting period shown is the year ended 31-12-1982. During this previous year, the appellant sold 58,776 shares of Ceat Tyres of India (hereinafter referred as "the Indian company’) to Indian residents Mr. H.V. Goenka and Mr. S. Goenka. These shares were sold at the rate of Rs. 204 per share for- a total consideration of Rs. 1,19,90,304. The assessee was allotted 68,850 shares of the Indian company at Rs. 100 per share in full and final satisfaction of the cost of machinery supplied by the appellant company to the Indian company. The appellant company was also allotted 96,390 shares at the rate of Rs. 125 per share on right basis. Thus, in the year 1961 itself, the appellant, namely, the foreign company, was in possession of 1,65,240 shares of the Indian company. Although the appellant company was also allotted substantial bonus shares in subsequent years, i.e., 19