Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4824 
Join Channel 
