Assessee computed capital gain on the transfer of shares held and owned by it of M/s SML Isuzu Ltd (Indian Company) to Isuzu Motors Ltd., Japan (non-resident) at based upon the terms of the Share Purchase Agreement (SPA) under which the transfer of the shares was made. During the year, the assessee had transferred 15,91,881 shares for a consideration which was payable in Japanese Yen 90,94,58,648 as agreed in SPA dated 25.11.2011.  The Assessing Officer adopted the different sale consideration. The Assessing Officer adopted an aggregate sale consideration as against the sale consideration accruing to assessee. Apart from this the Assessing Officer further adopted conversion rate of yen at Rs. 1.62 per Yen, whereas, the conversion rate on the date of agreement to sell i.e. 25.11.2011 was Rs. 1.49 per Yen as agreed in SPA as the consideration was payable in Yen by non-resident buyer to non-resident seller, both resident of Japan. The sale was made in Yen in Japan and the amount had been paid in Japan. While computing the capital gain, the Assessing Officer had adopted conversion rate (for converting capital gain in Yen to capital gain in Rs) i.e. telegraphic transfer buying rate at 0.62 instead of 0.6252. But under which method the same is adopted was not demonstrated by the Assessing Officer in the Assessment Order. The Hon’ble Tribunal further agreed to the contentions of the assessee that conversion rate for the purpose of computation of capital gain as per Rule 11UA of Income Tax Rules, 1962 is required to be adopted, the said rate was 0.6252 and as such the computation made by the assessee had been correctly adopted by it, appears to be just and proper. Thus, directed the Assessing Officer to adopt the actual rate of conversion i.e. 0.6252 after verifying the same and remanded the matter to file of AO.(AY. 2013-14)