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2012 (6) TMI 711 - AT - Income TaxDisallowance of exemption claimed u/s 545EC on investment made in REC Bonds - investment was made 8.5 months prior to date of transfer of the property subjected to capital gains - Held that:- Section 54EC clearly states that the investment in specified bonds is to be made "within a period 6 months after the date of such transfer". Had the legislature wanted to give liberty to the assessee to invest before or after the date of transfer, they would have explicitly said so, as has been provided in section 54 & 54F. Section 54EC clearly states that the investment in specified bond is to be made "within a period of six months after the date of such transfer …….." whereas in Section 54 and 54F which are adjacent to the Section 54EC, no such provision has been made - Since such specific words are not used in section 54EC, the intention of the legislature is clear and cannot be substituted with our own , the deduction u/s. 54EC for Rs. 50,000/- denied by the AO is correct and is upheld - against assessee.
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