Since, the new company and SBCS are both company limited RD empowered to assess the tax arising from shares transfer transaction. Moreover, in RD’s point of view the shares transfer by company limited should be paid at booked value of the shares unlike listed company which should be paid at and share transfer should be paid at market value of the shares. By implementation, the capital gain tax which the new company propose to pay for SBCS in process of SBCS’s shares transfer may lead the Company to be investigated in tax issue by RD.