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2014 (1) TMI 482 - AT - Income TaxRestriction of claim u/s 54EC of the Act – Held that:- Both the purchases made by the assessee were within the six months' period - the exemption provision has to be construed not transaction-wise but, financial year-wise - if the assessee is able to keep the six months' limit from the date of transfer of capital asset, but, still able to place investment of Rs. 50 lakhs each in two different financial years, the restrictive proviso will limit the claim to Rs. 50 lakhs only - the assessee here had placed Rs. 50 lakhs in two different financial years but within six months period from the date of transfer of capital asset, assessee was definitely eligible to claim exemption upto Rs. 1 Crore – Following Aspi Ginwala Shree Ram Engg. & Mfg. Industries v. Asstt. CIT [2012 (4) TMI 195 - ITAT AHMEDABAD] - Claim of the assessee for exemption upto Rs. 1 Crore has to be allowed in accordance with Section 54EC of the Act – Decided in favour of Assessee.
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