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    <title>2026 (6) TMI 856 - ITAT CHENNAI</title>
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    <description>Section 54EC exemption dispute turned on whether the second investment in specified bonds was made beyond the six-month period from transfer, but the Tribunal found the matter could not be finally decided without verifying whether REC bonds were actually unavailable during the relevant period and when the later investment was made. Because the claim depended on that factual verification, the disallowance was not conclusively upheld at this stage. The matter was set aside to the jurisdictional Assessing Officer for necessary examination, and the assessee obtained only partial relief. The dispute also arose in the context of processing under section 143(1) and rectification under section 154.</description>
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      <title>2026 (6) TMI 856 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=793475</link>
      <description>Section 54EC exemption dispute turned on whether the second investment in specified bonds was made beyond the six-month period from transfer, but the Tribunal found the matter could not be finally decided without verifying whether REC bonds were actually unavailable during the relevant period and when the later investment was made. Because the claim depended on that factual verification, the disallowance was not conclusively upheld at this stage. The matter was set aside to the jurisdictional Assessing Officer for necessary examination, and the assessee obtained only partial relief. The dispute also arose in the context of processing under section 143(1) and rectification under section 154.</description>
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