Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
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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