Assessee, a Singapore based company, transferred shares held in an Indian company, Genpact India, to its wholly owned Indian subsidiary for certain consideration. Assessee claimed exemption under section 47(Iv) of the Act. The AO allowed the exemption. Commissioner held  that transaction entered by assessee was sham and colourable device entered into to avoid payment of DDT under section 115-O. On appeal, Tribunal held that  there is  no justification for revision merely  on the ground that the recipient of income and was not entity which had either declared or paid dividend. On appeal High Court affirmed the order of the Tribunal.(AY. 2015-16)