Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2020 (9) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2020 (9) TMI 490 - AT - Income TaxExemption u/s 54EC - Investment in two different financial years - investment made in NHAI bonds - A.O. concluded that both the investment in NHAI bonds happened in the same financial year i.e. in the financial year 2013-14 - HELD THAT:- As per the provision of section 54EC(1) of the Act and its 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. The amendment in Finance (No.2 Act) 2014 relate to assessment year 2015-16 (i.e. insertion of second proviso to section 54EC(1) and the same applies prospectively for and from assessment year 2015-16. Since assessee had invested ₹ 71 lakhs in two different financial years and within six months from the date of transfer of the capital assets, the limit of ₹ 50 lakhs is per financial year. Hence, the assessee is eligible for deduction of ₹ 71 lakhs u/s 54EC - Decided in favour of assessee.
|