https://www.taxtmi.com/caselaws?id=450420 ITAT Mumbai held that capital loss of Rs. 386 crores claimed by assessee on sale of OCPS to related entity was genuine and allowable. The tribunal found that OCPS issuance and subsequent merger was not a colorable device, and the cost of acquisition of Rs. 686 crores was tenable for capital gain computation. Sale consideration was supported by independent merchant banker valuation report, making the transaction arm's length. AO's disallowance treating it as artificial loss was unjustified. Additionally, section 14A disallowance was restricted to exempt income earned, and Rule 8D application in MAT computation under section 115JB was deleted. en-us Thu, 29 Feb 2024 00:00:00 +0530 Wed, 28 Aug 2024 10:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450420 ITAT Mumbai held that capital loss of Rs. 386 crores claimed by assessee on sale of OCPS to related entity was genuine and allowable. The tribunal found that OCPS issuance and subsequent merger was not a colorable device, and the cost of acquisition of Rs. 686 crores was tenable for capital gain computation. Sale consideration was supported by independent merchant banker valuation report, making the transaction arm's length. AO's disallowance treating it as artificial loss was unjustified. Additionally, section 14A disallowance was restricted to exempt income earned, and Rule 8D application in MAT computation under section 115JB was deleted. Case-Laws Income Tax Thu, 29 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450420