The cost of shares of E for SGS was Rs. 10 per share and the shares had been transferred by SGS to the assessees at the same price, i. e., Rs. 10 per share. Therefore, no taxable perquisite arose. The reasons recorded by the Assessing Officer clearly showed that he had nowhere recorded his satisfaction with regard to the correctness of the findings of the Commissioner (Appeals) nor had he recorded his finding as to how he had reached the conclusion that income in the hands of the assessees had escaped assessment. The observations made by the Commissioner (Appeals) in case of SGS were not binding upon the Assessing Officer. (AY.2005-06)