Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Civil and electrical works incurred to render a newly acquired residential flat habitable were treated as allowable cost of improvement because the record showed the flat was not habitable on purchase, and the ad hoc restriction of the claim was unsustainable. Under the unamended section 54, deduction could not be denied merely because the capital gain was invested in more than one residential house, as the single-house restriction applied only prospectively from 1 April 2015. The unspent amount deposited in the Capital Gains Account Scheme under section 54(2) was also not taxable in the assessment year, since any disallowance could arise only after expiry of the prescribed three-year period.
Civil and electrical works incurred to render a newly acquired residential flat habitable were treated as allowable cost of improvement because the record showed the flat was not habitable on purchase, and the ad hoc restriction of the claim was unsustainable. Under the unamended section 54, deduction could not be denied merely because the capital gain was invested in more than one residential house, as the single-house restriction applied only prospectively from 1 April 2015. The unspent amount deposited in the Capital Gains Account Scheme under section 54(2) was also not taxable in the assessment year, since any disallowance could arise only after expiry of the prescribed three-year period.
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