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    <title>2023 (8) TMI 145 - ITAT DELHI</title>
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    <description>The Tribunal dismissed both appeals by the Revenue, upholding the decisions of the Commissioner (Appeals) on all contested grounds. The relief granted for expenses claimed under Section 48(1) was upheld, with the Tribunal finding the expenses reasonable and justified. The inclusion of Rs. 7.2 crore as part of the sale consideration was deemed taxable under long-term capital gain, supported by mutual agreement between the parties. The determination of Fair Market Value of shares as on 01.04.1981 was accepted based on expert valuation, with the Tribunal criticizing the AO&#039;s reliance on outdated rules and failure to consult the Departmental Valuation Officer.</description>
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      <link>https://www.taxtmi.com/caselaws?id=441166</link>
      <description>The Tribunal dismissed both appeals by the Revenue, upholding the decisions of the Commissioner (Appeals) on all contested grounds. The relief granted for expenses claimed under Section 48(1) was upheld, with the Tribunal finding the expenses reasonable and justified. The inclusion of Rs. 7.2 crore as part of the sale consideration was deemed taxable under long-term capital gain, supported by mutual agreement between the parties. The determination of Fair Market Value of shares as on 01.04.1981 was accepted based on expert valuation, with the Tribunal criticizing the AO&#039;s reliance on outdated rules and failure to consult the Departmental Valuation Officer.</description>
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