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    <title>2004 (1) TMI 323 - ITAT DELHI-E</title>
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    <description>Transfer of the NIIT shares was held to have occurred only when the bank released the shares on 5 May 1998, not under the earlier agreement, because the surrounding documents and conduct did not reliably prove an earlier completed sale. On that basis, the capital gains were computed with reference to the actual transfer date, and exemption under section 54F was denied because the assessee&#039;s claimed disposal of the residential property was not proved by credible evidence. Foreign travel expenses funded by the company were treated as part of the overall benefit linked to the share transaction, so no separate perquisite or unexplained expenditure addition survived. The addition for security services was sustained as a taxable perquisite.</description>
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      <title>2004 (1) TMI 323 - ITAT DELHI-E</title>
      <link>https://www.taxtmi.com/caselaws?id=65238</link>
      <description>Transfer of the NIIT shares was held to have occurred only when the bank released the shares on 5 May 1998, not under the earlier agreement, because the surrounding documents and conduct did not reliably prove an earlier completed sale. On that basis, the capital gains were computed with reference to the actual transfer date, and exemption under section 54F was denied because the assessee&#039;s claimed disposal of the residential property was not proved by credible evidence. Foreign travel expenses funded by the company were treated as part of the overall benefit linked to the share transaction, so no separate perquisite or unexplained expenditure addition survived. The addition for security services was sustained as a taxable perquisite.</description>
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