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...
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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