SRI GOPAL JALAN & COMPANY vs CALCUTTA STOCK EXCHANGEASSOCIATION LTD.

The Supreme Court interpreted 'allotment of shares' under Section 75(1) of the Companies Act, 1956, determining that the re-issue of forfeited shares does not constitute an allotment as it does not involve the appropriation of shares from unappropriated capital. Consequently, the company was not required to file a return for the re-issued shares, as this action is classified as a sale rather than an allotment. The court upheld the view that Section 75(5) serves merely as a precautionary measure to prevent disputes regarding the necessity of filing returns for re-issued forfeited shares.