Section 54F investment requirement prevails where developer-caused delays postpone residential property completion, delivery, or registration.

Section 54F should be construed liberally as a beneficial provision promoting reinvestment of long-term capital gains in a residential house. Its essential condition is investment of the capital gains towards purchase or construction within the prescribed period; completion, occupation, delivery and registration are not indispensable where delay is attributable to the developer or circumstances beyond the assessee's control. Accordingly, delayed completion, delivery and transfer of legal title to a residential villa does not defeat the exemption where the assessee has made the required investment.

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Issues: Whether exemption for investment of long-term capital gains in a residential property can be denied where completion, delivery and registration of the property occur beyond the stipulated period for reasons beyond the assessee's control.

Analysis: Section 54F is a beneficial provision intended to promote investment of capital gains in a residential house and must receive a liberal construction. Its essential requirement is investment of the capital gains towards purchase or construction of the residential property; completion of construction, occupation, delivery or registration within the prescribed period is not indispensable where the assessee has made the investment and the delay is attributable to the developer.

Conclusion: The assessee is entitled to exemption under Section 54F notwithstanding delayed completion, delivery and receipt of legal title to the residential villa due to factors beyond the assessee's control.

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