Tribunal grants appeal for exemption under section 54 for purchase of multiple houses

The Tribunal allowed the appeal, holding that the assessee is eligible for the claim of exemption u/s 54 for the purchase of 3 different residential houses. The judgments cited supported the interpretation that "a residential house" does not necessarily mean a singular unit, and the amendment introduced in 2014 does not apply retrospectively to the assessment year in question.

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Issues:
Interpretation of "a residential house" for deduction u/s 54 of Income-tax Act, 1961.

Detailed Analysis:

Issue 1: Interpretation of "a residential house" for deduction u/s 54:
The appeal was filed against an order passed for the assessment year 2013-14 regarding the disallowance of deduction u/s 54 of Rs. 49,62,490. The assessee sold 3 units of a property and purchased 3 units in the same city, claiming exemption. The Revenue argued that "a residential house" should be treated as one house, while the assessee contended for multiple units. Various judgments were cited, supporting the view that exemption under section 54 is available for more than one residential unit if used for residential purposes. The amendment in the statute w.e.f. 01.04.2015 was considered clarificatory. The Tribunal held in favor of the assessee, allowing the claim of exemption for the purchase of 3 different residential houses, stating that the amendment from 2014 would not apply to the assessment year 2013-14.

Conclusion:
The Tribunal allowed the appeal, holding that the assessee is eligible for the claim of exemption u/s 54 for the purchase of 3 different residential houses. The judgments cited supported the interpretation that "a residential house" does not necessarily mean a singular unit, and the amendment introduced in 2014 does not apply retrospectively to the assessment year in question.

This detailed analysis provides an overview of the issues involved in the legal judgment, the arguments presented by both parties, the relevant legal interpretations, and the final decision reached by the Tribunal.

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