Section 54F deduction cannot be refused for lack of sale deed registration when possession and ownership control are established.

Deduction under section 54F could not be denied merely because the conveyance deed for the residential property was not yet registered, where the assessee had paid consideration, obtained possession, and produced supporting documents such as the agreement to sell, power of attorney, possession letter, utility bills and photographs. The Tribunal applied the wider income-tax concept of ownership and treated registration of a formal sale deed as non-decisive once possession and dominion over the property were established. It also construed section 54F as a beneficial provision. The addition made by the Assessing Officer was therefore unjustified.

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Issues: Whether deduction under section 54F of the Income-tax Act, 1961 could be denied merely because the conveyance deed for the residential property had not yet been registered, despite the assessee having paid consideration and been put in possession.

Analysis: The assessee had furnished the agreement to sell, power of attorney, possession letter, payment details, and evidence of possession through utility bills and photographs. The property was already partly owned by the assessee, and the remaining share was acquired from her parents. The Tribunal treated the assessee as owner for the purposes of the Act in view of the wider concept of ownership applied in income-tax law. It relied on the principle that registration of a formal sale deed is not, by itself, decisive where possession and dominion over the property have been established, and that section 54F must be construed in a manner that gives effect to its beneficial object.

Conclusion: Deduction under section 54F could not be denied solely for want of registration of the sale deed, and the addition made by the Assessing Officer was not justified.

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