Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Section 54GB requires an investee company to have been incorporated in India within the stipulated period to qualify as an eligible company for capital-gains exemption. Commencement of business or manufacturing, acquisition of plant and machinery, or MSME registration cannot substitute for the legal incorporation date. A dormant company's later commencement of operations does not change its incorporation date under company law. Although incentive provisions may be construed liberally where ambiguous, an unambiguous exemption condition applies strictly. Investment in a company incorporated before the prescribed period therefore does not qualify for section 54GB exemption.
Section 54GB requires an investee company to have been incorporated in India within the stipulated period to qualify as an eligible company for capital-gains exemption. Commencement of business or manufacturing, acquisition of plant and machinery, or MSME registration cannot substitute for the legal incorporation date. A dormant company's later commencement of operations does not change its incorporation date under company law. Although incentive provisions may be construed liberally where ambiguous, an unambiguous exemption condition applies strictly. Investment in a company incorporated before the prescribed period therefore does not qualify for section 54GB exemption.
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