Section 54F exemption cannot be denied for technical non-deposit in the Capital Gain Account Scheme when house investment is otherwise complete.

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....Section 54F was construed as a beneficial provision whose substance is timely investment of capital gains in a residential house, and the Tribunal held that exemption could not be denied where that substantive requirement was met. The assessee's investment was found genuine and the discrepancy in the flat number was explained by developer records, which the Revenue did not rebut. Non-deposit of the unutilised amount in the Capital Gain Account Scheme before the due date under section 139(1) was treated as a technical lapse only, so the deduction was allowed in full and the capital gains addition was deleted.....