Section 54F exemption upheld where full payment and possession of the new house were completed within time, despite delayed registration.

Exemption under section 54F cannot be denied solely because the registered conveyance of a new residential house was executed after the stipulated period, where the assessee had paid the full consideration and taken possession within time. The decisive factor was completion of investment in the new house within the statutory period through payment and possession, while later registration was treated as non-controlling for section 54F purposes. On those facts, the exemption was held allowable and the Revenue's objection based only on delayed registration failed.

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Issues: Whether exemption under section 54F could be denied merely because the residential house was registered beyond the stipulated period, when the assessee had paid the full consideration and taken possession within time.

Analysis: The sale of the original capital asset was accepted. The decisive facts were that the assessee had paid the entire consideration for the new residential property within the prescribed period and had also taken possession of the property within that time. The property was later registered, but the delay in registration was treated as not controlling for the purpose of section 54F. The reasoning followed the principle that where the investment in the new house is completed by payment and possession within the statutory period, exemption cannot be refused solely because the registered conveyance was executed later.

Conclusion: Exemption under section 54F was allowable to the assessee, and the Revenue's objection on the basis of delayed registration failed.

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