Inverted-duty-structure refunds remain available for unchanged-rate apparel supplies despite trader status and require tax-period-specific computation...
Foundational assessment satisfaction is essential before initiating penalty for cash receipt of immovable-property sale consideration under section 27...
Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
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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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