During relevant year, assessee transferred some portion of its land to its holding company ‘S’ Ltd. . Assessee, relying upon provisions of section 47(v), did not offer profit arising from sale of land to tax under head ‘capital gains’ on ground that it was a 100 per cent subsidiary of ‘S’ Ltd.  Asseessing Officer held  that 25 shares of assessee company were held by nominees of holding company . Accordingly  he held that the assessee was not eligible for exemption of capital gains under section 47(v) . Allowing the appeal the Tribunal held that  nominees of holding company had no individual rights in said shares and those shares were held by them merely on behalf of holding company  hence the  assessee was entitled to exemption. On appeal by the revenue the Court affirmed the order of the Appellate Tribunal  (AY. 2007-08)