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The Commissioner Of Income-Tax vs Shri K Ramachandra Rao on 14 July, 2014

6.3 In the present case, the assessee purchased new asset on 05.10.2009 and had transferred the original asset on 8.01.2008. As per Section 54F (1) of the Act, the exemption would be available if the assessee purchased the residential house within two years after the date when transfer took place. As per the judgment of Hon'ble Karnataka High Court, the provisions of section 54F(4) would not be attracted in the event if the assessee has purchased or constructed the residential house within the period prescribed under section 54(1) of the Act. In the case in hand, there is no dispute with regard to the fact that the assessee had purchased within two years [the period prescribed u/s. 54[F(1)] a new asset on 05.10.2009 from the date of transfer of the original asset The Revenue has not cited or placed on record any contrary Judgment by the Hon'ble Jurisdictional High Court or Hon'ble Supreme Court. Therefore, respectfully following the ratio laid down by the Hon'ble Karnataka High Court in the case of CIT vs. K. Ramachandra Rao (supra), we hereby set aside the impugned order and direct the AO to re-compute the assessed income after granting the benefit of section 54F of the Act to the assessee."
Karnataka High Court Cites 9 - Cited by 88 - Full Document

Tarulata Shyam And Ors. vs Commissioner Of Income-Tax on 19 February, 1971

"7. When a provision for tolerance band is not prescribed in the statute, it cannot be open to us to read the same into the statutory provisions of section 50 C- no matter howsoever desirable such a provision be, even if that be so. What the provisions of section 50C clearly require is that when stated sales consideration is less than stamp duty valuation for the purposes of transfer, the stamp duty value will be subject to the safeguards built in the provision itself, taken as the sales consideration for the purposes of computing capital gains. Casus omissus, which broadly refers to the principle that a matter which has not been provided in the statue but should have been there, cannot be supplied by us, as, to do so will be clearly beyond the call and scope of our duty which is only to interpret the law is it exists. Hon'ble Supreme Court, in the case of Smt. Tarulata Shyam v. CIT [1977] 108 ITR 345 at has observed :
Calcutta High Court Cites 16 - Cited by 139 - Full Document
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