Appellant Entitled to Section 54 Deduction as Correct Interpretation Considers Payment and Possession Date of New Property.

Appellant Entitled to Section 54 Deduction as Correct Interpretation Considers Payment and Possession Date of New Property. https://www.taxtmi.com/highlights?id=79778 The appellant did not acquire a new residential property within the specified time period, failing the mandatory condition for deduction u/s 54. The CIT(A)-NFAC incorrectly invoked the "one year before the transfer" limb, concluding that the assessee is ineligible for deduction. However, the relevant date for computing the limitation u/s 54 in all three eventualities is the payment of consideration and possession of the new property. Judicial precedents support this interpretation. The assessee is entitled to the deduction u/s 54. en-us Sat, 27 Jul 2024 08:46:57 +0530 Sat, 27 Jul 2024 08:46:57 +0530 TaxTMI RSS Generator Appellant Entitled to Section 54 Deduction as Correct Interpretation Considers Payment and Possession Date of New Property. https://www.taxtmi.com/highlights?id=79778 The appellant did not acquire a new residential property within the specified time period, failing the mandatory condition for deduction u/s 54. The CIT(A)-NFAC incorrectly invoked the "one year before the transfer" limb, concluding that the assessee is ineligible for deduction. However, the relevant date for computing the limitation u/s 54 in all three eventualities is the payment of consideration and possession of the new property. Judicial precedents support this interpretation. The assessee is entitled to the deduction u/s 54. Highlights Income Tax Sat, 27 Jul 2024 08:46:57 +0530 https://www.taxtmi.com/highlights?id=79778