Capital gains under sections 45 and 48 are to be computed...

Capital gains under sections 45 and 48 are to be computed asset-wise, so each transfer of a long-term capital asset is a distinct source of gain. On that basis, section 54 exemption must be examined with reference to each transferred residential house and not by aggregating gains from multiple sales into one composite figure for investment in only one new house. The proviso allowing investment in two residential houses, where the capital gain does not exceed the prescribed limit, also operates transfer-wise. As the assessee sold multiple flats and invested in several residential houses, the statutory condition was not breached and the full section 54 claim was allowed; the earlier consistent treatment of the same claim supported this result.

---