Tax Exemption Ruling: Reasonable Technical Delays Accepted, but Ownership Requirement Strictly Interpreted for Capital Gains

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....ITAT partially allowed the appeal. The tribunal held that technical delays in reinvestment of capital gains should not automatically disqualify tax exemptions under Sections 54F and 54B, provided the fundamental intent of reinvestment is fulfilled. However, the exemption claim for agricultural land purchased in the brother's name was rejected, as the statute explicitly requires ownership in the assessee's name. The AO was directed to recompute taxable capital gains by allowing proportionate exemptions for investments made beyond prescribed time limits, while disallowing the exemption for the brother's land purchase.....