https://www.taxtmi.com/caselaws?id=776088 The ITAT Mumbai allowed the assessee's claim for exemption under section 54 despite the absence of possession and registration of the property due to a Supreme Court attachment order. The tribunal held that since the assessee had made substantial payment and entered into an agreement before filing the return, the purchase was effectively completed. The intention of section 54 is to relieve long-term capital gains tax where the consideration is invested in acquiring property. The tribunal rejected reliance on precedents related to the Transfer of Property Act, emphasizing a purposive interpretation of section 54 of the Income Tax Act. Consequently, the revenue's disallowance was overturned, and the exemption under section 54 was granted. en-us Wed, 01 Jan 2025 00:00:00 +0530 Tue, 05 Aug 2025 07:54:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776088 The ITAT Mumbai allowed the assessee's claim for exemption under section 54 despite the absence of possession and registration of the property due to a Supreme Court attachment order. The tribunal held that since the assessee had made substantial payment and entered into an agreement before filing the return, the purchase was effectively completed. The intention of section 54 is to relieve long-term capital gains tax where the consideration is invested in acquiring property. The tribunal rejected reliance on precedents related to the Transfer of Property Act, emphasizing a purposive interpretation of section 54 of the Income Tax Act. Consequently, the revenue's disallowance was overturned, and the exemption under section 54 was granted. Case-Laws Income Tax Wed, 01 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776088