Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Disallowance u/s 54F - Investment of Sale consideration for claiming exemption on LTCG - Advance was given for purchase of new residential property but the transaction was not materialized due to litigation - purchase of new residential property thereafter after getting refund of advance - failure to deposit into the capital gain account with the authorized banks - Since the assessee has fulfilled the substantive condition of Section 54F(1) of the Act by way of utilizing the sale consideration from sale of the capital asset (other than residential house) within two years of sale of original capital asset, assessee is eligible for deduction u/s 54F(1) - AT
Disallowance u/s 54F - Investment of Sale consideration for claiming exemption on LTCG - Advance was given for purchase of new residential property but the transaction was not materialized due to litigation - purchase of new residential property thereafter after getting refund of advance - failure to deposit into the capital gain account with the authorized banks - Since the assessee has fulfilled the substantive condition of Section 54F(1) of the Act by way of utilizing the sale consideration from sale of the capital asset (other than residential house) within two years of sale of original capital asset, assessee is eligible for deduction u/s 54F(1) - AT
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