Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
LTCG - Disallowance u/s 54 - construction of new house begun before the sale of the old house - The Tribunal emphasized that section 54 does not mandate the utilization of sale proceeds from the original asset for the purchase or construction of the new asset. - Referring to decisions from various High Courts, the Tribunal held that exemption under section 54F is applicable even if the investment is made from borrowed funds, as long as it meets the stipulated timeline. - Regarding the timeline for construction and possession, the Tribunal reiterated that the relevant date should be determined based on when the builder offered possession or cleared the balance dues, rather than earlier stages of construction.
LTCG - Disallowance u/s 54 - construction of new house begun before the sale of the old house - The Tribunal emphasized that section 54 does not mandate the utilization of sale proceeds from the original asset for the purchase or construction of the new asset. - Referring to decisions from various High Courts, the Tribunal held that exemption under section 54F is applicable even if the investment is made from borrowed funds, as long as it meets the stipulated timeline. - Regarding the timeline for construction and possession, the Tribunal reiterated that the relevant date should be determined based on when the builder offered possession or cleared the balance dues, rather than earlier stages of construction.
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