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Appeal of assessee is partly allowed.Provisions of section 2 (29A) read with provisions of section 2 (42A) of The Income Tax Act .

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Section 48 of the Income Tax Act, 1961 — Capital gains — Cost of Acquisition — The word accrued in section 48 means there has to be a right to receive the income arising from the contractual obligation between parties and such a right has to be with a corresponding liability of the other party from whom the income becomes due to pay that amount, thus, one party has the right and the other party has the liability to pay such right and liability has to originate from the understanding of all the terms and conditions of the contracting parties and the contractual obligation qua the transactions for which income can be said to have accrued to one party with the corresponding liability to pay on the other. To value the equity share Capital, all other items of the balance sheet other than equity capital and free reserve were required to be considered in the net asset value of those equity shares — Mrs Neelu Analjit Singh vs. Additional Commissioner of income tax [2020] 77 ITR (trib) 220 (Delhi)

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