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2020 (12) TMI 1364 - AT - Income TaxExemption u/s 54F - purchase of two residential properties at two different locations on two different dates - HELD THAT:- As per the provisions of the section 54F of the Act, the assessee has violated clause (ii) provided in sub-section (a) of section 54F of the Act, where it is stated that if the assessee purchases any new residential house other than new asset within a period of one year after the date of transfer of original asset, then the assessee is not entitled to claim exemption u/s.54F - In this case on perusal of the facts available on record, lower authorities have recorded categorical findings that assessee has purchased two different residential properties on two different dates and claimed exemption u/s.54F of the Act in contravention of provisions of law. Therefore, we are of the considered view that the assessee is not entitled for exemption u/s.54F of the Act. We are of the considered view that assessee is not entitled for exemption u/s.54F of the Act for purchase of two residential houses at two different locations on two different dates. The position remains same even after amendment to section 54F by the Finance Act, 2014 w.e.f. 01.04.2015. Therefore, we are of the considered view that the learned CIT(A) has right in denial of exemption claimed u/s.54F of the Act and hence, we are inclined to uphold the findings of the learned CIT(A) and dismiss the appeal filed by the assessee.
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