Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Determination of acquisition year for Long-Term Capital Gains hinges on transfer effected by handing over possession in part performance; registration date does not shift the year of acquisition once possession and consideration were transferred, so the FY 1996-97 Cost Inflation Index applies. The tribunal rejects need for independent third party corroboration where no adverse material exists and accords evidentiary weight to the registered document. On deduction of construction cost, the tribunal applied the principle of consistency and parity among similarly placed co owners, directing that construction and improvement costs accepted in co owners' cases be allowed mutatis mutandis to the assessee.
Determination of acquisition year for Long-Term Capital Gains hinges on transfer effected by handing over possession in part performance; registration date does not shift the year of acquisition once possession and consideration were transferred, so the FY 1996-97 Cost Inflation Index applies. The tribunal rejects need for independent third party corroboration where no adverse material exists and accords evidentiary weight to the registered document. On deduction of construction cost, the tribunal applied the principle of consistency and parity among similarly placed co owners, directing that construction and improvement costs accepted in co owners' cases be allowed mutatis mutandis to the assessee.
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