https://www.taxtmi.com/caselaws?id=176475 In a staged share sale, transfer for capital gains purposes occurred only when the contractual completion conditions were fulfilled and the shares were actually delivered, not on the earlier date of the share purchase agreement; the section 54EC claim therefore could not be rejected on the basis of an earlier transfer date. The difference between the agreed share price and book value could not be recharacterised as non-compete consideration under section 28(va) where the agreement fixed a composite price and contained no separate non-compete payment; any taxability would fall, if at all, under capital gains provisions. Professional and transactional expenses incurred wholly in connection with the share transfer were deductible in computing capital gains. en-us Fri, 22 May 2009 00:00:00 +0530 Fri, 13 Oct 2023 15:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176475 In a staged share sale, transfer for capital gains purposes occurred only when the contractual completion conditions were fulfilled and the shares were actually delivered, not on the earlier date of the share purchase agreement; the section 54EC claim therefore could not be rejected on the basis of an earlier transfer date. The difference between the agreed share price and book value could not be recharacterised as non-compete consideration under section 28(va) where the agreement fixed a composite price and contained no separate non-compete payment; any taxability would fall, if at all, under capital gains provisions. Professional and transactional expenses incurred wholly in connection with the share transfer were deductible in computing capital gains. Case-Laws Income Tax Fri, 22 May 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=176475