Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Revision u/s 263 - admissibility of deduction u/s 54F - CIT has misinterpreted the provision of law to hold that the assessee was ineligible to claim exemption u/s. 54F of the Act on the investment made in the land beyond two years - The Tribunal agreed with the assessee's interpretation of the law, stating that Section 54F allows a time period of three years for the construction of a house property to claim exemption. As the purchase of land was intended for construction, the Pr.CIT's interpretation was deemed incorrect. Consequently, the order of the Pr.CIT was set aside, and the appeal of the assessee was allowed.
Revision u/s 263 - admissibility of deduction u/s 54F - CIT has misinterpreted the provision of law to hold that the assessee was ineligible to claim exemption u/s. 54F of the Act on the investment made in the land beyond two years - The Tribunal agreed with the assessee's interpretation of the law, stating that Section 54F allows a time period of three years for the construction of a house property to claim exemption. As the purchase of land was intended for construction, the Pr.CIT's interpretation was deemed incorrect. Consequently, the order of the Pr.CIT was set aside, and the appeal of the assessee was allowed.
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