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...
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Execution and registration of the sale deeds transferred ownership rights and completed the transfer of immovable property for capital gains purposes, so short-term capital gains were taxable in AY 2014-15. Delayed receipt of consideration, dishonoured cheques, continued possession, or later disputes did not defer taxability where the registered deeds remained valid and were neither cancelled nor legally rescinded. The Tribunal upheld the addition on timing of transfer, but directed the AO to verify whether the same capital gain had already been assessed in AY 2016-17 and, if so, grant consequential relief to prevent double taxation.
Execution and registration of the sale deeds transferred ownership rights and completed the transfer of immovable property for capital gains purposes, so short-term capital gains were taxable in AY 2014-15. Delayed receipt of consideration, dishonoured cheques, continued possession, or later disputes did not defer taxability where the registered deeds remained valid and were neither cancelled nor legally rescinded. The Tribunal upheld the addition on timing of transfer, but directed the AO to verify whether the same capital gain had already been assessed in AY 2016-17 and, if so, grant consequential relief to prevent double taxation.
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