Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Capital gains exemption u/s 54F denied due to non-completion of construction within the stipulated period. The assessee entered into a Joint Development Agreement (JDA), receiving a residential villa in exchange for a plot of land. Despite a delay of over 7 years in completing construction against the 3-year period u/s 54F, the assessee failed to substantiate the explanation of a dispute among partners. No evidence was provided to demonstrate efforts made by the assessee to enforce rights under the agreement or ensure timely completion. Lack of vigilance and failure to exercise due diligence resulted in the dismissal of appeals by the Appellate Tribunal.
Capital gains exemption u/s 54F denied due to non-completion of construction within the stipulated period. The assessee entered into a Joint Development Agreement (JDA), receiving a residential villa in exchange for a plot of land. Despite a delay of over 7 years in completing construction against the 3-year period u/s 54F, the assessee failed to substantiate the explanation of a dispute among partners. No evidence was provided to demonstrate efforts made by the assessee to enforce rights under the agreement or ensure timely completion. Lack of vigilance and failure to exercise due diligence resulted in the dismissal of appeals by the Appellate Tribunal.
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