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2024 (9) TMI 1109

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..... venue s case before us places strong reliance on the statutory amendment in sec.54(1) vide Finance (No.2) Act, 2014 w.e.f. 01.04.2015 that such an option of re-investment of capital gains for purchasing a residential house abroad is no more available w.e.f. 01.04.2015. HELD THAT:- We are of the considered view that once the statutory provision itself stands amended and the assessee has made her in .....

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..... A)-National Faceless Appeal Centre, Delhi s DIN order no.ITBA/ NFAC/S/250/2023-24/1057232584(1), dated 19.10.2023, in proceedings u/s.143(3) of the Income Tax Act, 1961 (in short the Act ). Heard both the parties. Case file perused. 2. We advert to the assessee s pleadings. It emerges from a perusal thereof that her sole substantive grievance raised herein claiming sec.54 deduction of Rs. 1,06,00, .....

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..... gains arising from sale/transfer of a residential house, in purchase or construction of yet another residential house, as the case may be subject to fulfillment of certain other conditions. 4. The Revenue s case before us places strong reliance on the statutory amendment in sec.54(1) vide Finance (No.2) Act, 2014 w.e.f. 01.04.2015 that such an option of re-investment of capital gains for purchasi .....

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..... supra). We note that such an issue of interpretation of a subsequent amendment had never arisen before their lordships as it is evident from the substantial questions considered in para-3 of the decision. Be that as it may, we are of the considered view that once the statutory provision itself stands amended and the assessee has made her investment which is no more allowable, stricter interpretati .....

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