Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Section 54F is a beneficial capital gains exemption provision that requires liberal construction to promote investment in residential property. Where capital gains are invested in purchase or construction, delayed completion, possession or registration caused by circumstances beyond the assessee's control does not defeat the exemption. The article notes that establishing the qualifying investment is the essential requirement, rather than execution of a registered sale deed or completion within the stipulated period. On this basis, denial of the exemption was treated as illegal, the claimed Section 54F relief was granted, and the impugned order was set aside.
Section 54F is a beneficial capital gains exemption provision that requires liberal construction to promote investment in residential property. Where capital gains are invested in purchase or construction, delayed completion, possession or registration caused by circumstances beyond the assessee's control does not defeat the exemption. The article notes that establishing the qualifying investment is the essential requirement, rather than execution of a registered sale deed or completion within the stipulated period. On this basis, denial of the exemption was treated as illegal, the claimed Section 54F relief was granted, and the impugned order was set aside.
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