Proportionality in company penalty quantification requires aggravating and mitigating factors; mechanical multiplication of director liability is impe...
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Section 54 exemption was allowed for investment in more than one residential property, with the Tribunal accepting that the word "a" can encompass more than one house where supported by precedent. It also held that investments made after the due date for filing the income tax return could still be considered for exemption, even if not deposited in the capital gains scheme, and directed the Assessing Officer to allow relief on that basis. The result was that the assessee remained eligible for Section 54 relief on both the multiple-property investment and the delayed investment.
Section 54 exemption was allowed for investment in more than one residential property, with the Tribunal accepting that the word "a" can encompass more than one house where supported by precedent. It also held that investments made after the due date for filing the income tax return could still be considered for exemption, even if not deposited in the capital gains scheme, and directed the Assessing Officer to allow relief on that basis. The result was that the assessee remained eligible for Section 54 relief on both the multiple-property investment and the delayed investment.
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