Wrong FMV Date and Cost Basis: ITAT Reverses AO’s Computation of Capital Loss

RBS AA Holdings (Netherlands) B.V. Vs DCIT (ITAT Delhi) AO Applied Wrong Rule, Wrong Date & Wrong FMV—Section 50CA Not Attracted; Cost Must Be Actual ₹13.02/Share; Long-Term Capital Loss Allowed The Assessee, a Netherlands tax-resident, acquired 23.10 crore shares of its Indian subsidiary RBS Prime Services (India) Pvt. Ltd. in FY 2013-14 through a secondary purchase @ ₹13.02/share. In FY 2017-18, 14.67 crore shares were cancelled/reduced pursuant to an NCLT-approved capital-reduction scheme effective 20.11.2017, for a consideration of ₹10.09/share based on a valuation compliant wi...