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Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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ITAT ruled in favor of the assessee, allowing exemption under Section 54F. The tribunal found that the assessee effectively owned only one residential house at the time of transfer of original asset, having gifted another property to his daughter. The tribunal rejected technical objections by the Assessing Officer regarding the gift's validity and timing of property purchase. The court determined that the assessee met substantive requirements of Section 54F, including investing capital gains in a residential house property within prescribed timelines. The land purchased was considered valid for residential construction, thus qualifying for the exemption. Consequently, the Revenue's appeal was dismissed, upholding the assessee's claim for tax exemption.
ITAT ruled in favor of the assessee, allowing exemption under Section 54F. The tribunal found that the assessee effectively owned only one residential house at the time of transfer of original asset, having gifted another property to his daughter. The tribunal rejected technical objections by the Assessing Officer regarding the gift's validity and timing of property purchase. The court determined that the assessee met substantive requirements of Section 54F, including investing capital gains in a residential house property within prescribed timelines. The land purchased was considered valid for residential construction, thus qualifying for the exemption. Consequently, the Revenue's appeal was dismissed, upholding the assessee's claim for tax exemption.
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