EXEMPTION U/S 54G, Income Tax

[gangadharan m.v]

THE ASSESSEE AS INDIVIDUAL EARNED CAPITAL GAINS BY SALE OF HIS OLD INDUSTRIAL SHED AND REINVESTED THE PROCEEDS IN NON URBAN AREA IN NEW PLANT AND MACHINERY IN A PARTNERSHIP FIRM IN WHICH HE IS A PARTNER.INFACT HE HAS RELOCATED HIS STRUCTURAL ENGINEERING BUSINESS TO THE PARTNERSHIP FIRM. HE CLAIMED EXEMPTION OF CAPITAL GAINS U/S 54G. THE A O HOWEVER DIS ALLOWED THE STATING THAT THE REINVESTMENT SHOULD HAVE BEEN UNDER THE SAME P A N . HOWEVER READING SEC 54 G WHICH USES THE WORD UTILIZED, I FEEL A RESTRICTED INTERPRETATION IS .NOT JUSTIFIED PL GIVE YOUR VALUED OPINION