Deferred consideration contingent on revenue targets, accrual upon enforceable right. Cost of shares remanded. MFN clause for lower dividend tax rate remanded.

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....Deferred (contingent) consideration not accrued during relevant previous year as right to receive it was contingent upon achievement of revenue targets. Charging and computation provisions for capital gains to be read together. Accrual stage reached only when legally enforceable right to receive arises. Cost of acquisition of shares remanded for verification. Admission of additional ground regarding application of Most Favoured Nation clause for lower dividend tax rate as per India-Slovenia DTAA, remanded to AO for adjudication.....