section 46 (2) and exemption under section 54 EC possible?

[niketan kotadiya]

section 46 (2) and exemption under section 54 EC possible?

[DR.MARIAPPAN GOVINDARAJAN]

Which act your refer?

[KASTURI SETHI]

He is talking of Income Tax Act. Exemption under Section 54 EC is to be effective from 1.4.18. Clause 27 of Finance Bill, 2017 refers.

[DR.MARIAPPAN GOVINDARAJAN]

In my view it is not possible. Sethi Sir, what is your opinion?

[KASTURI SETHI]

Sir, Income Tax is not my field. I just traced out relevant Sections from internet with an intent to know reply from you for enrichment of my knowledge. Query should not remain unanswered. Thanks.

[DR.MARIAPPAN GOVINDARAJAN]

Please add income tax in your field so that viewers will be benefited much.

[KASTURI SETHI]

Sir, Thanks for reposing trust in me. I have no practical experience in Income Tax.

AI Summary

Exemption under section 54EC may not be available for transfers under section 46(2); applicability hinges on commencement timing. Question posed whether a transfer under section 46(2) can obtain exemption under section 54EC. Respondents observed that the exemption under section 54EC is tied to a legislative commencement introduced by the Finance Bill, 2017 and effective from 1.4.2018, and one participant expressed the view that section 54EC would not be available in the context of a section 46(2) transfer. The discussion recorded practitioner opinions and disclaimers of income tax expertise rather than a definitive legal conclusion.