Time Relevance of Expense: commission deductible when incurred; restructuring transfers, lease obligations upheld; unenforceable sale agreement bars l...
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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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