consideration on this ground. With respect to the deduction under
section 54EC of the Act being restricted to Rs. 50,00,000 as against ... 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
third issue relating to exemption under Section 54EC of the
Act, the assessee explained that the claim was on the basis that the
investments ... connection with transfer, it was not entitled to exemption under Section
54EC . He distinguished the Circular that had been relied upon stating that
that Circular
DEEPANSHI NEGI
Signing Date:12.11.2024
17:58:38
54EC of Income Tax Act, 19612. He was led to believe that if he used the
capital ... assumes no responsibility if the capital gains tax exemption under Section
54EC of the Income Tax Act is ultimately denied to the investor. This
Further, the investment with regard to the claim u/s 54EC has to be
made at any time within a period of six months after ... made by
the assessee as per the requirement of provisions of Sec.54EC . This
5
SushilaBhauraoDeshmukh
ITAno.76/Nag./2022
issue has not been verified
also
challenging the denial of benefit of reinvestment u/s. 54EC as not being applicable for
computing the book profit ... disallowance of Rs.50 lacs which
was claimed as exempt u/s. 54EC of the Act on the investment made in REC bonds
amount of Rs.90 Lakh received.
The assessee claimed deductions u/s 54EC for Rs. 40 (Forty) Lakh and
5
ITA No. 226/Kol/2022 ... latter registered agreement dated
26.09.2014 and allowed the deduction u/s 54EC of the Act from the
capital gains arising from such
fact that
the assessee changed the claim of deduction from Section
54EC to Section 54 of the Act and later from Section 54 to
Section ... after claiming exemption
of INR.5,50,00,000/- under Section 54EC of the Act. When the
Assessee was asked to substantiate the claim
grounds that the assessee has claimed deduction
u/s.54EC of the Act amounting to Rs.1.5 crore on account of
investment ... available as against LTCG deduction. To
be eligible for deduction u/s.54EC of the Act, investment in long-
term specified asset is required
after disallowing deduction u/s.54EC
of the Act of Rs. 41,00,000/- and deduction ... show less long-term capital gains by making claim
u/s.54EC of the Act without making any investment and this attempt
grounds that the assessee has claimed deduction
u/s.54EC of the Act amounting to Rs.1.5 crore on account of
investment ... available as against LTCG deduction. To
be eligible for deduction u/s.54EC of the Act, investment in long-
term specified asset is required