TMI Blog2015 (8) TMI 463X X X X Extracts X X X X X X X X Extracts X X X X ..... case of purchase of the property with sale proceeds it has to be reckoned within three years, in case of construction of new building utilising sale proceeds, the construction has to be completed within a period of three years of the sale. In this case, question of registration of document does not arise and it is a question of investment in construction of the new building. When it was found on f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... section 54 of the Income-tax Act, 1961 when the assessee had failed to construct her house within the stipulated period of three years ? (2) Whether the deduction under section 54 of the Income-tax Act can be allowed only on purchase of land without completion of the residential house within the period of three years as stipulated in the Income-tax Act ? (3) Whether the Income-tax Appellate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ceeds were used for construction of a new building. In order to get the benefit of section 54 of the Act, the investment of the sale proceeds have to be utilised by completing new construction of the building within three years of the sale of property. The learned Tribunal on fact found as follows : . . . Admittedly, in the present case, the assessee had invested the entire net consideration w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... benefit of section 54 of the Act, it does not appear that in case of purchase of the property with sale proceeds it has to be reckoned within three years, in case of construction of new building utilising sale proceeds, the construction has to be completed within a period of three years of the sale. In this case, question of registration of document does not arise and it is a question of investme ..... X X X X Extracts X X X X X X X X Extracts X X X X
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