Income Tax Act, 1967.

Shares, etc., deemed to be issued for public subscription.

331.—(1) Where—

(a) a company has issued any stocks, shares, or securities in respect of which a certificate under section 329 (2) has been given and continues to have effect, and

(b) the company subsequently issues any stocks, shares, or securities—

(i) offered or allotted to the holders as such, at or about the time of such subsequent issue, of the first-mentioned stocks, shares, or securities or of a particular class thereof, and

(ii) so offered or allotted on a basis calculated by reference to the respective holdings of those holders,

the stocks, shares, or securities which the company subsequently issues as aforesaid shall, for the purposes of section 329, be deemed to be issued for public subscription.

(2) Notwithstanding anything contained in section 329 (2) (b) (c) a certificate may be given under section 329 (2) in respect of any stocks, shares, or securities of a company which were or are issued as fully paid up and which, by virtue of subsection (1) of this section, are deemed to be issued for public subscription.

(3) Where a certificate is given under section 329 (2) in respect of any stocks, shares, or securities relief or repayment under section 329 (1) shall not be granted in respect of any dividend or interest on the stocks, shares, or securities which was payable before the date of the certificate.