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2015 (3) TMI 1379 - AT - Income TaxDeduction u/s 54EC - as per AO second tranche invested in the succeeding previous year, would not be eligible for deduction under section 54EC(1) AND the second investment was for a different financial year - DR submitted that investments made in two years when aggregated exceeded the limit of ₹ 50 lakhs set out in the section and therefore assessee ought not to have been given the relief - HELD THAT:- As relying on case C. JAICHANDER [2014 (11) TMI 54 - MADRAS HIGH COURT] from a reading of Section 54EC(1) and the first proviso, it is clear that the time limit for investment is six months from the date of transfer and even if such investment falls under two financial years, the benefit claimed by the assessee cannot be denied. It would have made a difference, if the restriction on the investment in bonds to ₹ 50,00,000/- is incorporated in Section 54EC(1) of the Act itself. However, the ambiguity has been removed by the legislature with effect from 1.4.2015 in relation to the assessment year 2015-16 and the subsequent years. For the foregoing reasons, we find no infirmity in the orders passed by the Tribunal warranting interference by this Court. The substantial questions of law are answered against the Revenue and these appeals are dismissed. We therefore find CIT(A) to be justified in giving the deduction under section 54EC to the assessee in full - Decided against revenue.
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