Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
The dominant issue is the relevant date for acquisition under section 54: the Tribunal applied the principle that actual handing over of possession (confirmed by an Occupation Certificate and possession letter) and completion of payment determine the acquisition date, not solely the date of registration. Applying that legal principle to the facts, the Tribunal found possession occurred before transfer of the original property, held the one year requirement satisfied, deleted the Assessing Officer's addition and allowed the deduction for the assessment year. (ITAT decision reflected.)
The dominant issue is the relevant date for acquisition under section 54: the Tribunal applied the principle that actual handing over of possession (confirmed by an Occupation Certificate and possession letter) and completion of payment determine the acquisition date, not solely the date of registration. Applying that legal principle to the facts, the Tribunal found possession occurred before transfer of the original property, held the one year requirement satisfied, deleted the Assessing Officer's addition and allowed the deduction for the assessment year. (ITAT decision reflected.)
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