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ITAT held that the term "purchase" in s. 54F(2) bears a wider connotation and is not confined to execution of a registered sale deed or actual possession; a liberal construction is warranted to effectuate the fiscal object of allowing rollover relief on reinvestment in residential property. The assessee's claim for exemption under s. 54F was upheld. Because the assessee's investment in the new residential house within the prescribed period was less than the net sale consideration of the original capital assets, the AO was directed to compute exemption pro rata: allow exemption in the proportion that the cost of the new house (investment made within the stipulated period) bears to the net sale consideration.
ITAT held that the term "purchase" in s. 54F(2) bears a wider connotation and is not confined to execution of a registered sale deed or actual possession; a liberal construction is warranted to effectuate the fiscal object of allowing rollover relief on reinvestment in residential property. The assessee's claim for exemption under s. 54F was upheld. Because the assessee's investment in the new residential house within the prescribed period was less than the net sale consideration of the original capital assets, the AO was directed to compute exemption pro rata: allow exemption in the proportion that the cost of the new house (investment made within the stipulated period) bears to the net sale consideration.
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