2024 (9) TMI 1109

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....e Assessee : Shri Divyesh Shah, C.A. For the Revenue : Shri Prashant Mahajan, Sr. AR ORDER PER SATBEER SINGH GODARA, J.M. This assessee's appeal for assessment year 2015- 2016 arises against the order of the learned CIT(A)-National Faceless Appeal Centre, Delhi's DIN & order no.ITBA/ NFAC/S/250/2023-24/1057232584(1), dated 19.10.2023, in proceedings u/s.143(3) of the Income Tax Act, 19....

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....e records before us, in her paper book running into 114 pages. 3. Now comes the dispute between the parties on the legal question of allowability of sec.54 deduction which is admissible to an assessee who re-invests the corresponding capital gains arising from sale/transfer of a residential house, in purchase or construction of yet another residential house, as the case may be subject to fulfil....

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....s CIT vs., Nirmal Textiles [1997] 224 ITR 378 (Guj.) that the position regarding applicability of the tax laws in such an instance has to be seen as on the date of transfer which is 12.06.2014 which is well before the cut-off date herein 01.04.2015 (supra). We note that such an issue of interpretation of a subsequent amendment had never arisen before their lordships' as it is evident from the subs....