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ITAT ruled that compensation expenses paid by the assessee to OXEECO were not directly connected to the share transfer to Harsco Investments Europe BV. The tribunal found the two transactions independent and unrelated, therefore rejecting the assessee's claim for deduction under Section 48. The compensation payment was deemed a separate transaction not incurred wholly and exclusively in connection with the share transfer. Consequently, the grounds of appeal were dismissed, upholding the lower authorities' decision and denying the claimed deduction while computing long-term capital gains.
ITAT ruled that compensation expenses paid by the assessee to OXEECO were not directly connected to the share transfer to Harsco Investments Europe BV. The tribunal found the two transactions independent and unrelated, therefore rejecting the assessee's claim for deduction under Section 48. The compensation payment was deemed a separate transaction not incurred wholly and exclusively in connection with the share transfer. Consequently, the grounds of appeal were dismissed, upholding the lower authorities' decision and denying the claimed deduction while computing long-term capital gains.
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