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TMI Blog2010 (8) TMI 153X X X X Extracts X X X X X X X X Extracts X X X X ..... annot be held entitled to exemption under s. 54B of the Act - Appeal is dismissed - 354 of 2010 - - - Dated:- 20-8-2010 - CORAM: HON'BLE MR. JUSTICE AJAY KUMAR MITTAL HON'BLE MR. JUSTICE MEHINDER SINGH SULLAR Mr. Aman Bansal, Advocate for the appellant. AJAY KUMAR MITTAL, J., This order will dispose of Income-tax Appeal Nos. 354 and 355 of 2010, filed at the instance of the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITD 313 (MUMBAI) is legally sustainable in the eyes of law? 2-Whether in the facts and circumstances of the present case, the action of the authorities below in ignoring the factum that the purchase consideration with expenses has been borne by the assessee/ appellant, as son of the assessee/appellant has no source of independent income, is legally sustainable in the eyes of law? 3-Whether in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2. The claim of the assessee in respect of deduction under Section 54B of the Act for the purchase of the agricultural land in the name of his son, amounting to Rs. 19,75,773/- was rejected. The assessee as well as the Revenue filed separate appeals before the Tribunal. The Tribunal dismissed both the appeals vide Annexure A-3. This is how the assessee is again in appeal before us. We have hea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... matter and interpret the meaning intended to be conveyed by the use of the words under the circumstances. The word "assessee" occurring in s. 54B must be interpreted in such a manner as to accord with the context and subject of its usage. A reading of s. 54B of the Act nowhere suggests that the legislature intended to advance the benefit of the said section to an assessee who purchased the agricul ..... X X X X Extracts X X X X X X X X Extracts X X X X
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