Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
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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