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 - Deduction claimed u/s 54 - ITAT allowed claim - The High Court notes that the issue revolves around long-term capital gains arising from an Apartment Buyers Agreement entered into before the property sale. - The ITAT's conclusion, aligning with previous case law, states that possession of the property was completed within three years from the sale, entitling the assessees to relief. Referring to precedent, the High Court reaffirms that the construction commenced within the mandated time frame, and the assessees fulfill the conditions under section 54 of the Act. The High Court dismisses the appeal of the Revenue, finding no substantial question of law raised and upholds the ITAT's decision.
LTCG - Deduction claimed u/s 54 - ITAT allowed claim - The High Court notes that the issue revolves around long-term capital gains arising from an Apartment Buyers Agreement entered into before the property sale. - The ITAT's conclusion, aligning with previous case law, states that possession of the property was completed within three years from the sale, entitling the assessees to relief. Referring to precedent, the High Court reaffirms that the construction commenced within the mandated time frame, and the assessees fulfill the conditions under section 54 of the Act. The High Court dismisses the appeal of the Revenue, finding no substantial question of law raised and upholds the ITAT's decision.
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