Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
ITAT held that the deeming fiction in section 50C is confined to computation of capital gains under section 48 and cannot be extended to the expression net consideration in section 54F. Section 54F operates on the actual consideration received or accrued, after transfer expenses, and the assessee satisfied the exemption condition by investing more than the actual sale consideration in a new residential house. Applying the settled rule that a deeming provision cannot be enlarged beyond its purpose, the Tribunal allowed full exemption under section 54F and held the capital gain not chargeable to tax; the agricultural land issue was left open as academic.
ITAT held that the deeming fiction in section 50C is confined to computation of capital gains under section 48 and cannot be extended to the expression net consideration in section 54F. Section 54F operates on the actual consideration received or accrued, after transfer expenses, and the assessee satisfied the exemption condition by investing more than the actual sale consideration in a new residential house. Applying the settled rule that a deeming provision cannot be enlarged beyond its purpose, the Tribunal allowed full exemption under section 54F and held the capital gain not chargeable to tax; the agricultural land issue was left open as academic.
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