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Section 54F relief was available because the Millennium Plaza property was treated as an office space and therefore a commercial property, not a residential house; the assessee was regarded as having only one residential house, so denial of the exemption had no basis. Even if the new asset at Parsvanath Exotica was transferred later, section 54F(3) affects taxation of the exempted capital gain in the year of transfer of the new asset and does not justify of the exemption in the year it was otherwise allowable. Agricultural receipts, including lease rent from agricultural land used for saplings and plantations, were also accepted as agricultural income because the assessee had supporting material and similar treatment had been accepted in earlier years and in connected precedent.
Section 54F relief was available because the Millennium Plaza property was treated as an office space and therefore a commercial property, not a residential house; the assessee was regarded as having only one residential house, so denial of the exemption had no basis. Even if the new asset at Parsvanath Exotica was transferred later, section 54F(3) affects taxation of the exempted capital gain in the year of transfer of the new asset and does not justify of the exemption in the year it was otherwise allowable. Agricultural receipts, including lease rent from agricultural land used for saplings and plantations, were also accepted as agricultural income because the assessee had supporting material and similar treatment had been accepted in earlier years and in connected precedent.
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