Assessing Officer on account of disallowance of deduction u/s 54EC of
the Act, though the proviso under specify the upper limit of 50 lakh ... deduction u/s 54EC of Rs.50,00,000/-.
While completing the assessment, the AO disallowed the commission
expenses
assessee has further claimed exemption of Rs.50
lakhs u/s.54EC by investing the same in Rural Electrification Corporation ... whereas the claim of the assessee is u/s.54EC.
Rejecting the arguments advanced by the assessee and distinguishing the
decision cited before
gains.
4. Without prejudice, the appellant firm be granted deduction u/s
54EC on account of investment in the bonds made by the partners
from ... capacity and also claimed the benefit of investment u/s.
54 and 54EC of the Act. The Assessing Officer was not impressed with
the contention
holding that the appellant was not
entitled to exemption u/s 54EC in respect of the investment in the
eligible bonds on the ground that ... consideration and accordingly, he was entitled to
claim the deduction u/s 54EC .
8. The learned CIT(A) erred in not appreciating that
held that investments in terms of provisions of sec.54EC made by the appellant is
eligible for deduction in terms of the said section ... condition for getting the relief in
terms of provisions of sec.54EC had not been complied with by the appellant. The relief
in terms
facts in directing the learned AO
to disallow exemption u/s 54EC of the ITA, 1961 amounting to Rs.17,00,000/- on the
analogy ... claim of exemption is not
admissible u/s 54EC of the Act.
3. In respect of first issue of exemption
erred in (& CIT(A) erred in confirming) disallowing
deduction u/s.54EC of Rs.50,00,000/-.
2.1 The Ld. AO erred ... erred in interpreting the provisions of
Section 54EC.
3. The appellant craves its right to add or modify or alter the Grounds of
appeal
confirming the action of the AO in confirming
the deduction u/s.54EC to Rs.50 lakhs, as against the deduction of Rs.
One Crore ... claimed by the appellant u/s.54EC of the Act.
2. The Ld.CIT(A) failed to appreciate that the investments in the
bonds
time limit for reckoning
the date for claiming exemption u/s 54EC of the Act within 6
months from the date on receipt of consideration ... that was invested in aforesaid
Bonds was claimed as deduction u/s 54EC of the Act. AO noticed
that the consideration on sale of capital
holding that the assessee was not entitled to exemption
u/s 54EC in respect of the investment in the eligible bonds on the grounds
that ... consideration and accordingly, he was entitled to claim the deduction u/s
54EC.
3.2 The ld CIT(A) erred in not appreciating that
