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„The key issue that arises for consideration is whether the
first proviso to section 54EC(1) of the Act would restrict
the benefit of investment of capital gains in bonds to that
financial year during which the property was sold or it
applies to any financial year during the six months period.
For better understanding of the issue, it would be apposite
to refer to section 54EC(1) of the Act, which reads as
under:
On a plain reading of the above said provision, we are of
the view that section 54EC(1) of the Act restricts the time
limit for the period of investment after the property has
been sold to six months. There is no cap on the investment
to be made in bonds. The first proviso to section 54EC(1)
of the Act specifies the quantum of investment and it
states that the investment so made on or after April 1,
2007, in the long-term specified asset by an assessee
during any financial year does not exceed fifty lakhs
rupees. In other words, as per the mandate of section
54EC(1) of the Act, the time limit for investment is six
months and the benefit that flows from the first proviso is
that if the assessee makes the investment of Rs. 50,00,000
in any financial year, it would have the benefit of section
54EC(1) of the Act.
"Notes on Clauses--Finance (No. 2) Bill, 2014:
Clause 23 of the Bill seeks to amend section 54EC of
the Income- tax Act relating to capital gain not to be
charged on investment in certain bonds.
The existing provisions contained in sub-section (1) of
section 54EC provide that where capital gain arises from
the transfer of a long-term capital asset and the assessee
has within a period of six months invested the whole or
part of capital gains in the long-term specified asset, the
proportionate capital gains so invested in the long-term
specified asset out of total capital gains shall not be
charged to tax. The proviso to the said sub-section
provides that the investment made in the long-term
specified asset during any financial year shall not exceed
fifty lakhs rupees.
This amendment will take effect from 1st April, 2015
and will, accordingly, apply in relation to assessment year
2015-16 and subsequent assessment years."
The Legislature has chosen to remove the ambiguity in
the proviso to section 54EC(1) of the Act by inserting a
second proviso with effect from April 1, 2015. The
Memorandum Explaining the Provisions in the Finance
(No. 2) Bill, 2014, also states that the same will be
applicable from April 1, 2015, in relation to assessment
year 2015-16 and the subsequent years. The intention of
the Legislature probably appears to be that this
amendment should be for the assessment year 2015-2016
to avoid unwanted litigations of the previous years. Even
otherwise, we do not wish to read anything more into the
first proviso to section 54EC(1) of the Act, as it stood in
relation to the assessees.