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Settlement Commission's order rejecting exemption u/s 54 on cash portion invested in purchasing property after sale of another property was invalid. Section 54 does not require disclosure of cash sale consideration while claiming exemption. Undisclosed income does not preclude Section 54 exemption if reinvestment is proved. Cash transactions for sale and purchase were established from seized materials. Grounds for denial were contrary to Section 54 provisions. High Court exercised judicial review, quashed denial of Section 54 exemption on cash portion, and decided in assessee's favor.
Settlement Commission's order rejecting exemption u/s 54 on cash portion invested in purchasing property after sale of another property was invalid. Section 54 does not require disclosure of cash sale consideration while claiming exemption. Undisclosed income does not preclude Section 54 exemption if reinvestment is proved. Cash transactions for sale and purchase were established from seized materials. Grounds for denial were contrary to Section 54 provisions. High Court exercised judicial review, quashed denial of Section 54 exemption on cash portion, and decided in assessee's favor.
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