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2017 (9) TMI 1460 - AT - Income TaxDisallowance of deduction claimed u/s 54EC - time limit for investment - Held that:- From a reading of Section 54EC 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 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 are of the view that there are differences in the judicial opinion on the issue. Thus following the decision of Hon'ble Madras High Court in the case of CIT vs S. Jaichander [2014 (11) TMI 54 - MADRAS HIGH COURT], dismiss the appeal of the Revenue on this ground.
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