The basic question is whether exemption u/s 54 for 1st year & u/s 54f for 2nd year for the purpose of the same property is admissible or not ? There is nothing in the Act that prohibits claim under section 54 & 54F simultaneously. In fact,conditions under both the section is different and therefore both these provisions are for different situation. Hence,if conditions of the said provisions are fulfilled,claim of exemption shall lie even if only one property is purchased to claim the LTCG arisen on sale of different assets.It is settled principal that section 54 & 54F are relief mechanism and therefore,if the conditions are fulfilled,the exemptions are allowable.There is no bar in section 54 or in section 54F against claiming exemption for time for the same property if the cost of the property is within the kimit arisen to the assessee.Reliance may be placed on the judgment in the case of Anagha Ajit Patenkar v ITO (2006) 9 SOT 685 (Mum).
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