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1 - 10 of 35 (0.25 seconds)Section 54F in The Income Tax Act, 1961 [Entire Act]
Section 147 in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
Section 148 in The Income Tax Act, 1961 [Entire Act]
Section 54B in The Income Tax Act, 1961 [Entire Act]
Section 45 in The Income Tax Act, 1961 [Entire Act]
Section 22 in The Income Tax Act, 1961 [Entire Act]
Commissioner Of Income-Tax vs T.N. Aravinda Reddy on 1 February, 1978
"3. The Assessing Officer, the appellate authority as well as the Tribunal rejected
the claim of the assessee in respect of the assessment year 1975-76 on the ground
that he did not become the owner of the property, as the said transaction was not
IT(IT)A No.258/Bang/2025
HanchipuraChannaiah Nandakishore, Bangalore
Page 10 of 16
evidenced by registration thereof as provided under section 17 of the Registration
Act. For the purpose of attracting the provisions of section 54, it is not necessary
that the assessee should become the owner of the property. Section 54 speaks of
purchase. Moreover, the ownership of the property may have different
connotations in different statutes. The question which arises for consideration
appears to be squarely covered by a decision of the Apex Court in CIT v. T.N.
Aravinda Reddy[1979] 120 ITR 461 where it has been held that the word
'purchase' occurring in section 54(1) of the Act had to be given its common
meaning, viz., buy for a price or equivalent of price by payment in kind or
adjustment towards a debt or for other monetary consideration. Each release in this
case was a transfer of the releasor's share for consideration to the release and the
transferee, the assessee, "purchased" the share of each of his brothers and the
assessee was, therefore, entitled to the relief under section 54(1).
Commissioner Of Income Tax vs Ravinder Kumar Arora on 17 September, 2011
13. Further, we find that the Hon'ble Jurisdictional Delhi High Court in
the cases of CIT v. Kamal Wahal [2013] 30 taxmann.com 34/214
Taxman 287/351 ITR 4 and CIT v. Ravinder Kumar Arora [2011] 15
IT(IT)A No.258/Bang/2025
HanchipuraChannaiah Nandakishore, Bangalore
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taxmann.com 307/203 Taxman 289/[2012] 342 ITR 38, has held
that new house purchased in the name of the spouse of the
assessee was eligible for claiming deduction under section 54F.
The provisions of section 54F are pari-materia with the provisions of
section 54 of the Act and thus, the principle derived equally applies to
section 54 as well. The Hon'ble Jurisdictional High Court has
also held in the various judgments that Purposive construction
is to be preferred as against the literal construction, more so
when even literal construction also does not say that the house
should be purchased in the name of the assessee only. Section
54F/54 of the Act are the beneficial provisions which should be
interpreted liberally in favour of the exemption/deduction to the
taxpayer and deduction should not be denied.