Initial subscription requirement for reinvestment alters capital gains rollover eligibility, limits eligible instruments and creates deemed conversion on loans For transfers after 28 February 1983, exemption under section 54E applies only if the assessee invests or deposits whole or any part of the net consideration in the new asset by initially subscribing to that asset; permissible new assets are limited to categories that the Central Government may notify (specified Government securities, special Unit Trust units, notified National Rural Development Bonds, and specified HUDCO debentures). If the assessee taking a loan or advance on the new asset after initial subscription, the asset is deemed converted on the date the loan or advance is taken; additional consideration received after that date in respect of such assets is similarly addressed.