Deduction under section 54 was denied because a long-term lease...

Deduction under section 54 was denied because a long-term lease of a plinth or plot for a proposed villa did not amount to purchase of a residential house. The assessee also failed to prove that construction had commenced or that substantial investment in the residential house was made within the statutory period after transfer of the original asset. The Tribunal rejected the contention that later restraint concerning Aamby Valley explained the non-completion, since the section 54 time limit and the contractual timelines had already expired. On these facts, there was no substantive compliance with section 54(1), and the claim was disallowed; the issue of investment after the due date under section 139(1) became infructuous.