Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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AAR held that Rule 86B restrictions apply to the taxpayer, preventing use of electronic credit ledger beyond 99% of total tax liability. The cumulative income tax paid by the partnership firm and its partners cannot be aggregated to satisfy the exemption threshold. Since no individual partner paid more than Rs. 1 lakh in income tax during the last two financial years, the exemption under Rule 86B is not applicable. The taxpayer must discharge tax liability using electronic credit ledger up to 99% of the total tax liability for monthly turnover exceeding Rs. 50 lakh.
AAR held that Rule 86B restrictions apply to the taxpayer, preventing use of electronic credit ledger beyond 99% of total tax liability. The cumulative income tax paid by the partnership firm and its partners cannot be aggregated to satisfy the exemption threshold. Since no individual partner paid more than Rs. 1 lakh in income tax during the last two financial years, the exemption under Rule 86B is not applicable. The taxpayer must discharge tax liability using electronic credit ledger up to 99% of the total tax liability for monthly turnover exceeding Rs. 50 lakh.
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