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    <title>2024 (9) TMI 260 - ITAT CHENNAI</title>
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    <description>Transfer for capital gains is determined by the date on which consideration is received and possession is handed over under the release deed; a later unilateral declaration cannot postpone the transfer. On that basis, the holding period was under 36 months, so the gain was short-term and section 54 relief was unavailable. The article also notes that a reconciliation supported by TDS and accounting method explained commission and closing balance differences, while cash freight paid above the permitted limit attracted disallowance under section 40A(3). Additions for sales tax-related items and cash deposits were sustained where the assessee failed to prove deductibility, source of funds, and creditor creditworthiness under section 68.</description>
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      <description>Transfer for capital gains is determined by the date on which consideration is received and possession is handed over under the release deed; a later unilateral declaration cannot postpone the transfer. On that basis, the holding period was under 36 months, so the gain was short-term and section 54 relief was unavailable. The article also notes that a reconciliation supported by TDS and accounting method explained commission and closing balance differences, while cash freight paid above the permitted limit attracted disallowance under section 40A(3). Additions for sales tax-related items and cash deposits were sustained where the assessee failed to prove deductibility, source of funds, and creditor creditworthiness under section 68.</description>
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