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 ...
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Exemption u/s 54EC - Assessee has not been able to raise any material contention to dispute this position. He has only submitted that the assessee wanted to invest the long- term capital gain in purchase of another residential property and unable to find the suitable property, he finally invested the amount in long- term capital gain bonds on 21. 01.2020. In my opinion, this aspect is irrelevant to decide the eligibility of assessee for exemption under section 54EC, which specifically provides that the investment in eligible bonds is required to be made by the assessee within a period of six months from the date of transfer of the long-term capital asset in order to claim the exemption on account of long- term capital gain - AT
Exemption u/s 54EC - Assessee has not been able to raise any material contention to dispute this position. He has only submitted that the assessee wanted to invest the long- term capital gain in purchase of another residential property and unable to find the suitable property, he finally invested the amount in long- term capital gain bonds on 21. 01.2020. In my opinion, this aspect is irrelevant to decide the eligibility of assessee for exemption under section 54EC, which specifically provides that the investment in eligible bonds is required to be made by the assessee within a period of six months from the date of transfer of the long-term capital asset in order to claim the exemption on account of long- term capital gain - AT
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