Capital-gains consideration for unquoted share transfers cannot be replaced with a later transaction's value without statutory basis.

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....Capital-gains computation for an unquoted equity-share transfer uses the consideration actually received or accruing from that transfer; a notional value may replace it only under an express statutory fiction. The prescribed fair-market-value substitution did not apply where the declared consideration exceeded fair market value. Demat records and contemporaneous delivery instructions established completion of the earlier transfer, and later settlement of the purchaser's liability could not alter its transfer date or consideration. A subsequent transfer under a different ownership and contractual structure could not substitute its consideration for the earlier transaction, particularly where conditions had not crystallised the final price. The capital-gains addition was therefore deleted.....