Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Section 54F relief was available where the assessee booked an under-construction flat, paid substantially the entire consideration within the statutory period, and obtained registration later. The Tribunal treated the transaction as falling within the construction limb of Section 54F, so the three-year period applied and delayed execution of the sale deed did not defeat the claim. It further held that, even on a purchase analysis, the critical factor was acquisition of substantial domain over the property through timely substantial payment, not the date of registration alone. On these facts, the deduction was allowed and the denial by the lower authorities was reversed.
Section 54F relief was available where the assessee booked an under-construction flat, paid substantially the entire consideration within the statutory period, and obtained registration later. The Tribunal treated the transaction as falling within the construction limb of Section 54F, so the three-year period applied and delayed execution of the sale deed did not defeat the claim. It further held that, even on a purchase analysis, the critical factor was acquisition of substantial domain over the property through timely substantial payment, not the date of registration alone. On these facts, the deduction was allowed and the denial by the lower authorities was reversed.
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