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2014 (1) TMI 902 - ITAT HYDERABADValidity of order u/s. 143(3) r.w section 147 of the Act - Claim of deduction u/s 54F of the Act - Whether the purchase of property by the sister in law and nephew of the assessee can be considered as the investment by the assessee to substantiate his claim for deduction under S.54 - Held that:- Though beneficial provisions have to be interpreted liberally, there is a limit for such liberal interpretation, and it cannot be stretched beyond that point - the assessee had claimed exemption for the investment made by the sister-in-law and nephew stating that they are blood relations. The provisions of S.54 speak of investment in residential house property, that too only by an assessee, being an individual or an Hindu Undivided Family - The statutory provision as such does not include assessee's wife or assessee's minor children - the Courts have taken a liberal interpretation of the statutory provisions and extended the exemption available under S.54 to the assessee, even in the cases of investments in the names of spouse and minor children of the assessee - such liberal interpretation cannot be extended beyond a point so to cover investments made in the names of other blood relations or other relations – there was no infirmity in the order – Decided against Assessee.
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