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Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
An allotment letter from a developer is considered an agreement to purchase a property, and payments made through banking channels establish its veracity. The valuation date for determining any deemed gift is the date of the first payment, not the later date of property transfer. CBDT circulars recognize allotment letters as agreements for construction, granting capital gains set-off benefits to purchasers. Applying this analogy, the assessee's allotment letter and cheque payments from June 2010 constitute an agreement, precluding additions u/s 56(2)(vii)(b)(ii) for deemed gifts. The Assessing Officer erred in considering the valuation date as October 2014, and the addition is deleted by the Appellate Tribunal.
An allotment letter from a developer is considered an agreement to purchase a property, and payments made through banking channels establish its veracity. The valuation date for determining any deemed gift is the date of the first payment, not the later date of property transfer. CBDT circulars recognize allotment letters as agreements for construction, granting capital gains set-off benefits to purchasers. Applying this analogy, the assessee's allotment letter and cheque payments from June 2010 constitute an agreement, precluding additions u/s 56(2)(vii)(b)(ii) for deemed gifts. The Assessing Officer erred in considering the valuation date as October 2014, and the addition is deleted by the Appellate Tribunal.
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