Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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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