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ITAT set aside the CIT(A)'s disallowance and directed the AO to delete the addition and grant exemption under s.54 in respect of all seven adjacent residential units. The Tribunal held that where multiple units in the same complex/adjoining units effectively constitute one residential house, the phrase "a residential house" (construed as "one residential house") includes multiple contiguous units on the same floor, and thus the assessee's investment qualifies for s.54 relief. The Tribunal rejected the AO's application of the post-amendment concept to deny relief and remitted for compliance, ordering grant of exemption to the extent claimed by the assessee.
ITAT set aside the CIT(A)'s disallowance and directed the AO to delete the addition and grant exemption under s.54 in respect of all seven adjacent residential units. The Tribunal held that where multiple units in the same complex/adjoining units effectively constitute one residential house, the phrase "a residential house" (construed as "one residential house") includes multiple contiguous units on the same floor, and thus the assessee's investment qualifies for s.54 relief. The Tribunal rejected the AO's application of the post-amendment concept to deny relief and remitted for compliance, ordering grant of exemption to the extent claimed by the assessee.
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