Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
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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