ITAT Ahmedabad dismissed the Revenue’s appeal. It upheld the deletion of the ₹4.30 crore addition because cutting the value of the unlisted shares from ₹2,000 to ₹1,800 properly reflected cost apportioned under an NCLT-approved demerger, read with ICDS-VIII.
It also upheld the deletion of the trading-loss disallowances, since the exchange trades were backed by contract notes, demat records and STT, and no material linked the assessee to accommodation entries.