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The High Court of Madhya Pradesh held that a Hindu Undivided Family (HUF) was not entitled to deduction under section 54 of the Income Tax Act for capital gains. This decision was based on the interpretation that the term "assessee" in section 54 referred only to living persons, not artificial juridical persons like HUFs. The court's decision was in line with a previous ruling in Shrigopal Rameshwardas v. Addl. CIT [1979] 119 ITR 980.
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