Beneficial owner determination under GPA negates capital gains liability; fuel, bonus and TDS additions reconsidered and adjusted.

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....GPA coupled with an agreement to sell resulted in the agent becoming the beneficial owner of the residential plot, so the vendor assessed was not liable for capital gains on the transfer since consideration was received by the beneficial owner. Additions under unexplained expenditure for fuel were deleted after finding fuel costs proportionate to transport receipts and no cogent departmental challenge to books; related addition of Rs. 1,45,16,786 was deleted. Bonus payments recorded in books were sustained as legitimate business expenses. Disallowance for non-deduction of tax on interest paid to banks was deleted on exemption and admitted loan amortization evidence; disallowance for interest to NBFCs may be deleted if those recipients have included and paid tax on the amounts.....