Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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