directing the Assessing Officer to grant deduction u/s 54EC in respect of
the investment made in specified bonds. According to the revenue the
investments ... prior to sale of property and
hence the criteria prescribed u/s 54EC is not satisfied and therefore
assessee is not entitled for deduction
because of the reason that the AO has not granted
exemption ufs.54EC for the reason that the sale
consideration was treated under the head ... order of CIT(A) allowing the claim of
exemption under section 54EC of the Act. For this Revenue as raised following
ground No.4: -
Page
invested out of the an amount of Rs.19,53,571/- in 54EC & an
amount of Rs.13,55,795/- was invested to purchase ... Rural Electrification Bond on 31.07.2012 to
avail the exemption u/s 54EC . The assessee invested
assessee would be
deprived for claiming exemption u/s 54 and 54EC . As observed above
as per Section 45 r.w.s 48 whole
account of exemption u/s. 54
and 54EC of the Act treating the said house as
being 'Constructed by the assessee and not
considering ... account of
2
exemption u/s. 54EC of the Act without
considering the date of purchase of REC
bonds
whether the Ld. CIT(A) erred in allowing the claim u/s 54EC of
the Act, of making investment in RECL Bonds ... Lacs only and that the second proviso to section 54EC is
clarificatory in nature.
2. The Appellant prays that the order
which he directed the Assessing Officer to allow exemption under Section 54EC of the Income Tax Act to the assessee.
2. The assessee ... sale proceeds in Rural Electrification Bonds- REC 54EC Series III on 24-3-2004. The investment was in the joint names of herself, being
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
erred in
allowing the claim of Rs 1 crore u/s 54EC of The Income Tax Act,
1961.
2) On the facts and circumstances ... erred in
allowing claim of Rs 1 crore u/s 54EC of the income tax act, 1961,
when the assessee has purchased both the capital
addition of Rs.
50,00,000/- on account of exemption u/s. 54EC of the Act
without considering the date of purchase of REC bonds ... disallowance of claim u/s 54EC of
the Act at Rs. 50,00,000/- and addition of Rs.
14,07,474/- towards purported amounts received
