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    <title>2016 (7) TMI 1097 - ITAT MUMBAI</title>
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    <description>Section 54EC relief was treated as available where capital gains arose on transfer of a depreciable long-term capital asset, because the deeming fiction in section 50 was confined to computation of capital gains and did not extend to deny exemption provisions. The text also states that section 54EC does not distinguish between depreciable and non-depreciable assets. A summary adjustment under section 143(1)(a) was described as impermissible where the claim was not an apparent incorrect claim on the face of the return. The result stated is that the deduction was allowable and the disallowance at the processing stage was unsustainable.</description>
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      <title>2016 (7) TMI 1097 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=330499</link>
      <description>Section 54EC relief was treated as available where capital gains arose on transfer of a depreciable long-term capital asset, because the deeming fiction in section 50 was confined to computation of capital gains and did not extend to deny exemption provisions. The text also states that section 54EC does not distinguish between depreciable and non-depreciable assets. A summary adjustment under section 143(1)(a) was described as impermissible where the claim was not an apparent incorrect claim on the face of the return. The result stated is that the deduction was allowable and the disallowance at the processing stage was unsustainable.</description>
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