Capital Gain Deductibility: proportionate IPO and PMS expenses held allowable against capital gains where netting and nexus to transfer are established.

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....Capital gain computation: proportionate Initial Public Offer (IPO) expenses that are netted from sale proceeds and shown by invoices and prospectus apportionment satisfy the requisite nexus as "expenditure incurred wholly and exclusively in connection with such transfer" and are deductible under section 48, subject to verification that the netted proceeds were credited to the shareholder. Portfolio Management Services (PMS) fees deducted under the PMS arrangement and remitted as net proceeds are likewise allowable against capital gains where amounts were actually deducted and no prior show-cause was issued; AO directed to permit these deductions.....