Assessee and her husband entered into share purchase agreement to sell her shares in four companies. In the computation the assessee claimed that  consideration agreed between parties for sale of its shares was Rs. 2.70 crores minus tax component of Rs. 90.74 lakhs.  Assessee had agreed to pay tax component as per clause 7(1) of share purchase agreement. She claimed deduction under ‘capital gains’ on tax component under section 48 of the Act Assessing Officer disallowed the claim. Commissioner (Appeals) allowed appeal in part and appeal before Tribunal, had been dismissed. On appeal the Court held that value of shares would be amount agreed between parties excluding tax components but tax component should be distributed among both sellers. Therefore, assessee would be entitled for deduction of only 50 per cent of tax component proportionate to her shareholding. Relied on CIT v. Gillanders Arbuthnot & Co (1973) 87 ITR 407 (SC), CIT v. George Henderson & Co Ltd (1967) 66 ITR 622 (SC)