Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
The Appellate Tribunal addressed two key issues: 1. Denial of cost of improvement in LTCG computation: AO's denial based on absence of improvement reference in sale deed and payment timing after notice issuance. Tribunal upheld CIT(A)'s deletion, noting AO's similar addition in spouse's case and lack of Revenue challenge. 2. Denial of deduction u/s 54: AO's denial due to alleged failure to meet construction deadline. Tribunal affirmed CIT(A)'s finding of asset sale, purchase, and compliance with u/s 54 conditions. Spouse's case comparison showed inconsistency. Tribunal ruled in favor of taxpayer, dismissing Revenue's grounds.
The Appellate Tribunal addressed two key issues: 1. Denial of cost of improvement in LTCG computation: AO's denial based on absence of improvement reference in sale deed and payment timing after notice issuance. Tribunal upheld CIT(A)'s deletion, noting AO's similar addition in spouse's case and lack of Revenue challenge. 2. Denial of deduction u/s 54: AO's denial due to alleged failure to meet construction deadline. Tribunal affirmed CIT(A)'s finding of asset sale, purchase, and compliance with u/s 54 conditions. Spouse's case comparison showed inconsistency. Tribunal ruled in favor of taxpayer, dismissing Revenue's grounds.
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