Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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Section 54 capital-gains exemption remains available where capital gains are invested in a new residential house within the prescribed period, even if the unutilised amount was not deposited in the Capital Gains Account Scheme before the return-filing due date. Treating section 54 as a beneficial provision, the Tribunal regarded the deposit requirement as procedural where the substantive investment condition was met. The taxpayer's share in the jointly acquired property exceeded the capital gain and the purchase occurred before the extended return-filing due date. Accordingly, the section 54 deduction was allowed and the disallowance was deleted.
Section 54 capital-gains exemption remains available where capital gains are invested in a new residential house within the prescribed period, even if the unutilised amount was not deposited in the Capital Gains Account Scheme before the return-filing due date. Treating section 54 as a beneficial provision, the Tribunal regarded the deposit requirement as procedural where the substantive investment condition was met. The taxpayer's share in the jointly acquired property exceeded the capital gain and the purchase occurred before the extended return-filing due date. Accordingly, the section 54 deduction was allowed and the disallowance was deleted.
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