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Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
Section 48 requires capital gains to be computed using the consideration actually received or accruing, unless an applicable deeming provision permits substitution with fair market value. Redemption proceeds from non-cumulative preference shares therefore cannot be replaced by the price of equity shares in the same company, because the share classes carry different rights and no additional consideration was established. The provision for unquoted-share transfers and the rule for unascertainable consideration do not apply where redemption consideration is ascertainable. A claim for enhanced acquisition cost following capital reduction and consolidation requires factual verification of acquisition records, share identity, legal effect and cost allocation; it cannot be raised as a pure legal ground without an existing factual record.
Section 48 requires capital gains to be computed using the consideration actually received or accruing, unless an applicable deeming provision permits substitution with fair market value. Redemption proceeds from non-cumulative preference shares therefore cannot be replaced by the price of equity shares in the same company, because the share classes carry different rights and no additional consideration was established. The provision for unquoted-share transfers and the rule for unascertainable consideration do not apply where redemption consideration is ascertainable. A claim for enhanced acquisition cost following capital reduction and consolidation requires factual verification of acquisition records, share identity, legal effect and cost allocation; it cannot be raised as a pure legal ground without an existing factual record.
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