High Court held that the assessee did not sell the entire shareholding and continued to hold a portion of the shares in subsequent years, which militated against the allegation of a colourable device. In view of the concurrent findings of fact by the CIT (A) and the Tribunal in favour of the assessee, the Court held that no substantial question of law arose for consideration. SLP of revenue dismissed on account of delay of 325 days and merits due to low tax effect. Question of law kept open  (AY. 2015-16)