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The Appellate Tribunal (ITAT) upheld the appellate order granting relief under Section 54F to the assessee trust. The ITAT found the trust to be a private trust for identified beneficiaries (not a charitable AOP), such that trust income is attributable to beneficiaries; the transaction-purchase of land, sale of flat and reinvestment of capital gains into a residential house-would, absent the trust, have been effected in beneficiaries' names and qualified for exemption under Section 54. Consequently, the CIT(A)'s allowance of Section 54F relief was affirmed and the revenue's challenge dismissed.
The Appellate Tribunal (ITAT) upheld the appellate order granting relief under Section 54F to the assessee trust. The ITAT found the trust to be a private trust for identified beneficiaries (not a charitable AOP), such that trust income is attributable to beneficiaries; the transaction-purchase of land, sale of flat and reinvestment of capital gains into a residential house-would, absent the trust, have been effected in beneficiaries' names and qualified for exemption under Section 54. Consequently, the CIT(A)'s allowance of Section 54F relief was affirmed and the revenue's challenge dismissed.
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