Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Disallowance of deduction u/s 54B - assessee did not file return under Section 139(1) of the Act and he has not deposited the sale proceeds in the capital account - The correlation between the investment and receipt of sale proceeds within the time stipulated in Section 54B of the Act has duly been demonstrated by the assessee. In view of the above, the appeal of the assessee is allowed and the Assessing Officer is directed to grant deduction under Section 54B - AT
Disallowance of deduction u/s 54B - assessee did not file return under Section 139(1) of the Act and he has not deposited the sale proceeds in the capital account - The correlation between the investment and receipt of sale proceeds within the time stipulated in Section 54B of the Act has duly been demonstrated by the assessee. In view of the above, the appeal of the assessee is allowed and the Assessing Officer is directed to grant deduction under Section 54B - AT
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