Restriction of Input Tax Credit under Rule 86A applies only to fraudulently or ineligible availed credit; mere wrongful recipient availment is insuffi...
Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
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Section 54F requires purchase of the new residential house within the statutory period, and an unregistered banakhat by itself was not enough to prove completion of purchase within that time frame. Because the substantial payment was made more than one year before transfer and the registered sale deed was executed beyond two years after transfer, the deduction could not be sustained on the existing record; the issue was restored for limited verification of the flow of funds and linkage with sale proceeds. The addition under section 69 also required fresh factual examination, as the bank statements and documentary evidence were not properly verified and it was unclear whether all material had been before the AO. Both matters were remanded.
Section 54F requires purchase of the new residential house within the statutory period, and an unregistered banakhat by itself was not enough to prove completion of purchase within that time frame. Because the substantial payment was made more than one year before transfer and the registered sale deed was executed beyond two years after transfer, the deduction could not be sustained on the existing record; the issue was restored for limited verification of the flow of funds and linkage with sale proceeds. The addition under section 69 also required fresh factual examination, as the bank statements and documentary evidence were not properly verified and it was unclear whether all material had been before the AO. Both matters were remanded.
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