Tribunal held that the assessee has produced evidence viz., entries in the books, declaration made in delivery instruction slips at the time of transfer of shares, statement of its director, unequivocal stand taken by GIDPL in the meeting of directors, etc. to substantiate its claim that the shares were received by the assessee from GIDPL as loan and there is nothing on record to arrive at a conclusion that GIDPL has waived its right in any manner to recover shares or equivalent value thereof from the assessee, there is no benefit chargeable to tax under s. 28(iv) in the hands of the assessee and S. 41(1) was also not attracted. Tribunal also held that the Assessing Officer had not rejected the books of account and addition was also deleted; hence, the adjustment to book profit was deleted. (AY. 2019-20)