Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
Issue concerns eligibility for capital gains exemption under Section 54 where the replacement dwelling was an under construction flat. The article explains the Tribunal treated acquisition as effected on discharge of balance consideration and taking possession on completion, not on execution of the booking agreement. Applying the substance of the transaction, possession/payment on completion (07-01-2015) was held to be the relevant date for the two year compliance measured from transfer (28-10-2013), therefore the statutory conditions were satisfied and the exemption was allowed.
Issue concerns eligibility for capital gains exemption under Section 54 where the replacement dwelling was an under construction flat. The article explains the Tribunal treated acquisition as effected on discharge of balance consideration and taking possession on completion, not on execution of the booking agreement. Applying the substance of the transaction, possession/payment on completion (07-01-2015) was held to be the relevant date for the two year compliance measured from transfer (28-10-2013), therefore the statutory conditions were satisfied and the exemption was allowed.
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