Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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Assessee entitled to deduction under 54F where the entire sale consideration was invested in purchase of a residential house within one year, notwithstanding that only part had been deposited in a capital gains account scheme before filing the return. Tribunal applied the principle that the legislative purpose is to ensure reinvestment of sale proceeds into residential property rather than formal deposit into the capital gains account scheme; consequently compliance is satisfied by actual investment within the prescribed period. Reliance was placed on the reasoning in K. Ramchandra Rao affirming substance over form for 54F relief.
Assessee entitled to deduction under 54F where the entire sale consideration was invested in purchase of a residential house within one year, notwithstanding that only part had been deposited in a capital gains account scheme before filing the return. Tribunal applied the principle that the legislative purpose is to ensure reinvestment of sale proceeds into residential property rather than formal deposit into the capital gains account scheme; consequently compliance is satisfied by actual investment within the prescribed period. Reliance was placed on the reasoning in K. Ramchandra Rao affirming substance over form for 54F relief.
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