Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie l...
Profit-element taxation limits additions for unaccounted flat-sale receipts and grey-market purchases, while reliable search records support partial a...
Non-participating bidders cannot disturb concluded liquidation sales on speculative prejudice, while costs for such challenges must remain proportiona...
Payment to an agreement holder to extinguish enforceable specific-performance rights arising from an agreement for sale qualifies as expenditure incurred wholly and exclusively in connection with a property transfer. Where the payment clears the holder's claim, improves the transferor's title and enables the sale, it is deductible when computing capital gains under section 48. The Tribunal treated the payment as analogous to expenditure incurred to remove existing rights that obstruct a transfer, deleted the related capital-gains addition, and allowed the appeal.
Payment to an agreement holder to extinguish enforceable specific-performance rights arising from an agreement for sale qualifies as expenditure incurred wholly and exclusively in connection with a property transfer. Where the payment clears the holder's claim, improves the transferor's title and enables the sale, it is deductible when computing capital gains under section 48. The Tribunal treated the payment as analogous to expenditure incurred to remove existing rights that obstruct a transfer, deleted the related capital-gains addition, and allowed the appeal.
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