Proportionality in company penalty quantification requires aggravating and mitigating factors; mechanical multiplication of director liability is impe...
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ITAT held that deduction under section 54F could not be denied merely because the residential house was purchased from close relatives or because the Revenue suspected a colourable device. The sale of shares and purchase of the flat were supported by contemporaneous material, including demat records, a registered purchase agreement, developer confirmation, and post-purchase utility records in the assessee's name; the use of a power of attorney for execution of the deed was also not questioned by the registering authority. As the transactions remained undislodged by cogent evidence, the Tribunal treated the arrangement as permissible tax planning within the legal framework and directed deletion of the addition.
ITAT held that deduction under section 54F could not be denied merely because the residential house was purchased from close relatives or because the Revenue suspected a colourable device. The sale of shares and purchase of the flat were supported by contemporaneous material, including demat records, a registered purchase agreement, developer confirmation, and post-purchase utility records in the assessee's name; the use of a power of attorney for execution of the deed was also not questioned by the registering authority. As the transactions remained undislodged by cogent evidence, the Tribunal treated the arrangement as permissible tax planning within the legal framework and directed deletion of the addition.
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