Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Section 54 relief was available where the assessee invested capital gains in an under-construction residential flat within the prescribed period. The ITAT held that booking a flat with a builder, supported by allotment letters and proof of payment, amounts to investment in construction of a residential house. Completion of construction, registration, or handing over of possession within the statutory period was not indispensable on these facts, especially where the delay was attributable to the developer and the assessee had made substantial payment within time. The Revenue's challenge failed, and the deduction under section 54 was upheld.
Section 54 relief was available where the assessee invested capital gains in an under-construction residential flat within the prescribed period. The ITAT held that booking a flat with a builder, supported by allotment letters and proof of payment, amounts to investment in construction of a residential house. Completion of construction, registration, or handing over of possession within the statutory period was not indispensable on these facts, especially where the delay was attributable to the developer and the assessee had made substantial payment within time. The Revenue's challenge failed, and the deduction under section 54 was upheld.
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