Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Exemption u/s 54F(1) - The three parts/limbs cannot be intermingled to deny the benefit of 54F(1) to the assessee. The third part/ limb being applicable to the facts of the case and it is not in dispute that the assessee has constructed the residential building within three years from the date of transfer of long standing asset, the benefit flowing from the said Section cannot be denied on the premise that the land was purchased prior to one year. In our opinion, this interpretation of the revenue is wholly untenable and would defeat the object and purport of the provision. - HC
Exemption u/s 54F(1) - The three parts/limbs cannot be intermingled to deny the benefit of 54F(1) to the assessee. The third part/ limb being applicable to the facts of the case and it is not in dispute that the assessee has constructed the residential building within three years from the date of transfer of long standing asset, the benefit flowing from the said Section cannot be denied on the premise that the land was purchased prior to one year. In our opinion, this interpretation of the revenue is wholly untenable and would defeat the object and purport of the provision. - HC
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