Document Fragment View
Fragment Information
Showing contexts for: paripassu in Assistant Commissioner Of Income Tax, ... vs Sh. Narayanappa Ramanna, Bangalore on 16 April, 2024Matching Fragments
9. The Hon'ble Madras High Court in the case of CIT Vs. Smt. V. R. Karpagam reported in [2015] 373 ITR 127 (Mad) had categorically held that the principles mentioned in section 54 of the Act is to be applied paripassu to section 54F of the Act. In view of the aforesaid judicial pronouncement, we hold that assessee is entitled to the benefit of section 54F of the Act in respect of all the units received by the assessee pursuant to the JDA, since the relevant Assessment year is prior to the amendment to section 54F of the Act (i.e., 01.04.2015). It is ordered accordingly.