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TMI Blog2020 (9) TMI 490X X X X Extracts X X X X X X X X Extracts X X X X ..... GEORGE K., JUDICIAL MEMBER: This appeal at the instance of the assessee is directed against CIT(A) order dated 26.11.2018. The relevant assessment year is 2013-14. The solitary effective ground raised reads as follows: "Ground No.2: The learned CIT(A) erred in upholding the addition of Rs. 21,00,000/- and also failed to appreciate the facts and the provisions of the act under section 54E(1) and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Further, the letter of allotment received from NHAI also reflects the date of allotment at 31.3.2013 and 31.7.2013 respectively. However, the credit of the same was reflected in the Demat account of the assessee on 10.5.2013 and 5.9.2013 respectively. 3. The A.O. passed an order of assessment u/s 143(3) of the Act (order dated 29.1.2016), wherein he did not give deduction for a sum of Rs. 21 lakh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... HAI allotment letter of Rs. 50 lakhs and Rs. 21 lakhs on 23.3.2013 and 20.7.2013 respectively, copy of the sale deed, computation of income for assessment year 2013-14, the case laws relied etc. 6. The Ld. D.R. on the other hand strongly supported the order of assessment and the CIT(A) in restricting the claim of deduction to a sum of Rs. 50 lakhs. 7. We have heard the rival submissions and peru ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... apathi Hegde in ITA No.964/Bang/2016 of ITAT Bangalore. 8. Since assessee had invested Rs. 71 lakhs in two different financial years and within six months from the date of transfer of the capital assets, the limit of Rs. 50 lakhs is per financial year. Hence, the assessee is eligible for deduction of Rs. 71 lakhs u/s 54EC of the Act. It is ordered accordingly. 9. In the result, the appeal filed ..... X X X X Extracts X X X X X X X X Extracts X X X X
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