Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Deduction for reinvestment of long-term capital gains into agricultural land is analysed with focus on whether a purchase constitutes a transfer for tax relief. The document reasons that where purchase consideration was paid, possession received, and the purchase deed ultimately registered, the transaction satisfies the legal attributes of transfer and purchase for claiming relief; consequently the reinvestment deduction is available. The decision rejects treating the sale proceeds as unexplained receipts and concludes that the purchasers entitlement to deduction accrues when the transfer takes effect, allowing the claim under the relevant deduction provision.
Deduction for reinvestment of long-term capital gains into agricultural land is analysed with focus on whether a purchase constitutes a transfer for tax relief. The document reasons that where purchase consideration was paid, possession received, and the purchase deed ultimately registered, the transaction satisfies the legal attributes of transfer and purchase for claiming relief; consequently the reinvestment deduction is available. The decision rejects treating the sale proceeds as unexplained receipts and concludes that the purchasers entitlement to deduction accrues when the transfer takes effect, allowing the claim under the relevant deduction provision.
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