Deduction u/s 54 was allowable in case capital gains were utilized within time specified but sale deed was not registered

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Dr. Sheela Puttabuddi Vs ITO (ITAT Bangalore)

Conclusion: Utilisation of capital gains within time specified would entitle assessee to claim deduction under section 54, notwithstanding fact that new asset was registered beyond period specified under section 54, which according to assessee was beyond her control and was to be liberally construed.

Held: Assessee was a Doctor by profession and had derived capital gains from sale of flat on various dates and assessee claimed exemption u/s 54 to the extent of Rs.1,26,00,000.  AO and CIT(A) denied the claim of exemption for the reason that since assessee was not able to purchase a new asset by reinvesting in a new residential property within the stipulated time the exemption u/s 54 could not be granted to assessee. Assessee had sold the property on various dates during the relevant assessment year, namely, A.Y.2015-2016. Admittedly, assessee had neither purchased nor constructed the residential house within the due date specified and also the proceeds from the sale of original asset was deposited by the assessee in a capital gains account scheme with the State Bank of India. The solitary question which required to be adjudicated was whether assessee was entitled to the claim of exemption u/s 54 of Rs.1,26,00,000 even though the new residential house was registered beyond the stipulated period of 2 years as per the provisions of section 54 of the I.T.Act. It was held that considering the benevolent nature of section 54, the utilisation of the capital gains within the time specified would entitle assessee to the claim of deduction under section 54 notwithstanding the fact that the new asset was registered beyond the period specified under the I.T.Act, which according to the assessee was beyond her control and was to be liberally construed. It was held by various Hon’ble Courts that application of beneficial provisions must be liberal to accommodate the rules laid down broadly to verify compliance and must not be interpreted literally, unlike charging sections which were to be construed strictly. The bonafides of assessee could not be doubted, since assessee had made deposits into the capital gains scheme immediately and thereupon made payments to the developer to acquire the new house property. Assessee was also prevented by reasonable cause since the funds had already been utilized and was forced to acquire an asset due to the reason beyond her control. The section 54 of the I.T.Act being benevolent in nature, it should be liberal in interpreting the provisions of section 54 of the I.T.Act considering the fact that the new house was eventually acquired, out of the same capital gains utilized, which had been brought on record and not in dispute. Assessee was entitled to the claim of deduction to the extent of Rs.1,26,00,000 and directed AO to allow the claim u/s 54 to the said extent.

FULL TEXT OF THE ORDER OF ITAT BANGALORE

This appeal at the instance of the assessee is directed against CIT(A)’s order dated 18.11.2019. The relevant assessment year is 2015-2016.

2. There is a delay of 44 days in filing this appeal. The assessee has filed a petition for condonation of delay accompanied by an affidavit stating therein the reasons for belated filing of this appeal. We have perused the reasons stated in the affidavit for filing this appeal belatedly. We find that there is sufficient cause for the late filing of the appeal and the delay cannot be attributed to the assessee. Hence, we condone the delay and proceeded to dispose of the appeal on merits.

3. The solitary issue argued is whether the CIT(A) is justified in confirming denial of exemption u/s 54 of the I.T.Act.

4. The brief facts of the case are as follows:

The assessee is a Doctor by profession. For the assessment year 2015-2016, the return of income was filed on 07.09.2015 declaring total income of Rs.2,10,030. The assessee had disclosed income from profession, interest income and capital gains. The assessment was selected for scrutiny and notice u/s 143(2) of the I.T.Act was issued. During the course of scrutiny assessment, it was noticed that the assessee had claimed a sum of Rs.1,26,00,000 as exempt u/s 54 of the I.T.Act. The details of the same were called for and it was noticed that the assessee has not invested in a residential house but paid a sum of Rs.1,26,00,000 to one Sri.B.Suresh for purchase agricultural land of 2 acres at Kolar Taluk. It was evidenced by unregistered agreement for purchase of an agricultural land. No registered document was produced by the assessee. Therefore, the A.O. held that the assessee has not made any investment in residential property for claiming exemption u/s 54 of the I.T.Act. The relevant finding of the A.O. in this regard reads as follows:-

Transfer of residential house property for a sum of Rs.1,26,00,000/- dated 18.04.2015:

On perusal of the evidences and documents produced during the scrutiny assessment proceedings, it is noticed that a sum of Rs.1,26,00,000/- has been claimed exemption u/s 54 of the Income Tax Act, 1961. However, the assessee has not invested in a residential house property, but the assessee has paid a sum of Rs.1,26,00,000/- to one Shri B.Suresh for the purchase of an agricultural land of 2 acres bearing SY No.71 of (Block No.1) of Chakkarasanahalli Village, Narasapura Hobli, Kolar Taluk Evidencing an unregistered agreement for the agricultural land. No registered documents were produced by the assessee. As per the documents produced by the assessee, it is very clear that, the assessee has made investment in an agricultural land, hence the exemption claimed u/s 54 of the Income Tax Act, 1961 for a sum of Rs.1,26,00,000 is disallowed.”

5. Aggrieved, the assessee preferred an appeal to the first appellate authority. During the course of appellate proceedings, the assessee submitted that before the due date of filing of the return she had invested Rs.1,26,00,000 in purchase of agricultural land, which was to be converted by the builder into non-agricultural land and she was entitled to receive a built up house property on such land. It was submitted that the conversion of the land from agricultural to non-agricultural could not be obtained by the developer and as such constructed house could not be handed over to the assessee. It was further submitted that later on the said builder had offered an alternative residential property and she accepted the offer. The assessee had filed additional evidence vide letter dated 19.11.2018 by enclosing copy of the purchase deed dated 22.03.2018 showing purchase of house property. The additional evidence was forwarded to the A.O. and remand report was called for. The A.O. vide letter dated 11.04.2019 submitted the remand report. The assessee also filed rejoinder to the same vide letters dated 09.09.2019 and 30.09.2019. The CIT(A), however, rejected the contentions of the assessee and dismissed the appeal of the assessee. The relevant finding of the CIT(A) in regard to the claim of exemption u/s 54 of the I.T.Act amounting to Rs.1,26,00,000 reads as follows:-

“5.5 The submissions of appellant and reports of the AO have duly been considered. It is noted that during remand proceedings, vide letter dated 15.03.2019 the appellant had herself requested the AO to disregard the agreement for purchase of agricultural land in respect of her claim of exemption under Section 54 of the Act. So as such the appellant has accepted that she was not eligible to claim exemption under Section 54 of the Act in relation to investment of Rs. 1,26,00,000/- as made for purchase of agricultural land. Considering above the ground of appeal 4 of the appellant is dismissed.

5.6 As regards additional evidence filed by the appellant, this is observed that the same is not relevant to any of the grounds of appeal of the appellant. Through this additional evidence the appellant has sought adjudication of issue as to ‘whether she was eligible for exemption under Section 54 of the Act on the basis of purchase of house property on 22.03.2018 i.e. after the assessment had been passed by the AO and also after a period of three years from the date of sale of the original asset (the original asset being sold on 23.04.2014 08.09.2014, 30.10.2014, 14.11.2014 and 24.11.2014)’. So vide the additional evidence the appellant has sought adjudication on a ground of appeal which neither. formed part of the grounds of appeal taken up in Form no. 35 nor the same had been filed by her as additional grounds of appeal. The ground of appeal is very specific and relates to investment of Rs 1,26,00,000/- in purchase of agricultural land. So this cannot be extended to include all claims related to Section 54 of the Act. Since the ground of appeal sought to be adjudicated itself does not exist, so the admission of additional evidence on such an issue does not arise. Considering above the additional evidence as submitted by the appellant is not admitted.”

6. Aggrieved, the assessee has filed the present appeal before the Tribunal. The assessee has filed a paper book comprising of 60 pages enclosing therein copy of computation of total income and acknowledgement of filing of return for the relevant assessment year 2015-2016, copy of the application for admission of additional evidence under Rule 46A, copy of the sale deed of the new asset dated 23.03.2018, computation of capital gains filed before the A.O. during the remand proceedings, copy of the written submissions filed before the lower authorities, the case laws relied on, etc. The learned AR reiterated the submissions made before the Income Tax Authorities.

7. The learned Departmental Representative, on the other hand, submitted that the assessee had advanced a sum of Rs.1,26,00,000 to one Sri.B.Suresh for purchase of an agricultural land. It was stated by the learned DR that the residential house purchased in 2018 does not qualify for exemption u/s 54 of the I.T.Act, since the said asset was not purchased within 2 years from the date of sale of original asset. Therefore, it was submitted that the CIT(A) has correctly rejected the claim of the assessee.

8. We have heard rival submissions and perused the material on record. The solitary question which requires to be adjudicated is whether the assessee is entitled to the claim of exemption u/s 54 of the I.T.Act of Rs.1,26,00,000 even though the new residential house was registered beyond the stipulated period of 2 years as per the provisions of section 54 of the I.T.Act. The assessee is a Doctor by profession and had derived capital gains from sale of flat on various dates and the assessee claimed exemption u/s 54 of the I.T.Act to the extent of Rs.1,26,00,000. The A.O. and the CIT(A) denied the claim of exemption for the reason that since the assessee was not able to purchase a new asset by reinvesting in a new residential property within the stipulated time the exemption u/s 54 of the I.T.Act cannot be granted to the assessee. The assessee has sold the property on various dates during the relevant assessment year, namely, A.Y.2015-2016. The details of the same has been tabulated at page 2 of the assessment order. As per the provisions of section 54 of the I.T.Act, the assessee ought to have purchased the residential house within 2 years or constructed a residential house within 3 years from the date of sale of the original asset (the original asset was sold on 26.03.2015 for a total consideration of Rs.1,26,00,000 and the assessee ought to have either purchased the new asset on or before 25.03.2017 or construct within 3 years i.e. on or before 25.03.2018). Admittedly, the assessee has neither purchased nor constructed the residential house within the due date specified. It is also an admitted position that the proceeds from the sale of original asset was deposited by the assessee in a capital gains account scheme with the State Bank of India on 26.03.2015 itself. The copy of statement of capital gains account scheme is placed at page 31 of the paper book filed by the assessee.

9. It is the case of the assessee that there was an arrangement with the developer Sri.B.Suresh, who developed the joint property of the assessee along with other co-owners wherein the assessee and other co-owners received the flats. Since the said developer Sri.B.Suresh was very well known to the assessee, request was made to the developer Sri.B.Suresh to identify the land and construct a residential house. It is admitted fact that the assessee made the payment as advance to Sri.B.Suresh of Rs.1,25,00,000 directly from the capital gains account scheme maintained by the assessee with State Bank of India. It is stated that the said payment was made in lieu of investing in purchase of new asset. The said payment to Sri.B.Suresh was made by the assessee on 08.05.2015. This aspect is clear from the capital gains account scheme produced by the assessee. Accordingly the AR submitted that the intention to reinvest was very clear, since the payment was made in advance to Sri.B.Suresh. It was submitted that as per the provisions of section 54 of the Act the said capital gains have been utlised for the purchase of new asset and the assessee is eligible for exemption u/s 54 of the I.T.Act. The learned AR further submitted that due to various diverse reason the said developer i.e. Sri. B. Suresh to whom the assessee had made payment for identifying the land and construct of new house could not fulfill the same and later point of time after due deliberations the developer Sri. B. Suresh identified an already constructed house and got the said property registered in the name of the assessee. It was stated that the said Developer Sri. B. Suresh made the payment directly to the vendors for and on behalf of the assessee. Thus, the same fortifies the fact that Sri. B. Suresh was in agreement with the assessee for reinvesting the capital gains on behalf of the assessee. The learned AR has primarily argued that the claim of deduction is allowable on the short point of making deposits into the capital account scheme before filing the return of income, which fact is reiterated in the remand report and not in dispute. The assessee contends that the deposit and utilisation of the capital gains before the filing of the return of income for the impugned assessment year, would suffice to be eligible to the claim of deduction under section 54 of the I.T.Act. The assessee has further submitted that the capital gains have been utilised within the period prescribed under section 54 of the I.T.Act and the main requirement to make a claim under section 54 of the I.T.Act, is to utilise the capital gains for the purpose of acquisition of a residential house, which in the instant case was fulfilled, albeit with a delay in registration of the property. The learned AR has further argued that the registration of the property, similar to the completion of the construction of a house property would signify the completion of the procedure for investment, the latter part was not to be treated as absolute, considering the benevolent nature of section 54 of the I.T.Act. The assessee has submitted that the utilisation of the capital gains within the time specified would suffice to make the assessee eligible to the claim of deduction under section 54 of the I.T.Act, and the assessee should not be treated as not being eligible for the deduction claimed. The claim of the assessee is that she is entitled to the deduction under section 54 of the I.T.Act, since she has complied with the requirement of section 54 of the I.T.Act, in so far as investing the capital gains from the sale of the house property into a capital gains account scheme account before filing the return of income as required under section 54 of the I.T.Act. Alternatively, the assessee has contested that the capital gains were uti!ised within the period prescribed under section 54 of the I.T.Act, since the amount of capital gains have been utilised for the acquisition of the house property.

10. It is not disputed by the assessee that the new house property has been registered beyond the period prescribed, i.e., two years after the date of sale of the house property or alternatively after three years permitted for construction of the property. However, it is contended that the requirement of the section is that the capital gains must have been “utilized” within the specified period and the funds must be out of the control of the assessee. We have observed that the assessee in the instant case has indeed paid the developer the amounts of Rs.1.26 crores before filing the return of income and also affirmed by the Assessing officer in the remand report. The assessee’s claim of having utilized the capital gains before filing the return of income, has thus been fulfilled and the assessee is eligible for the claim of deduction u/s 54 of the I.T.Act, in so far as the assessment year 2015-2016 is concerned. It is also relevant to consider the registered sale deed dated 23.03.2018, wherein the assessee has purchased the residential house in which the de eloper Sri. B. Suresh is also a consenting witness to the said sale deed who has made payment for and behalf of the assessee and the stamp duty also has been paid by him which clearly establish the fact that the advance paid by the assessee to Sri. B. Suresh was with an intention to reinvest the proceeds of capital gains in acquiring a new property and consequently the conditions as specified in section 54 of the I.T.Act having been complied. The relevant extract of the clause in the registered sale deed dated 23.03.2018 in which the developer Sri. B. Suresh has also signed as a consenting witness is reproduced hereunder for clarity:

“1. WHEREAS the PURCHASER further represented that certain disputes arose between them and in order to put an end to the disputes, the PURCHASER and Sri. B. SURESH agreed to purchase a house for the PURCHASER and Sri. B. Suresh alongwith the Purchaser, negotiated and accepted the offer of the VENDORS and Sri. B. SURESH has paid on behalf of the Purchaser the entire consideration of Rs. 1,18,20,000/- (Rupees one Crore eighteen lakhs twenty thousand only) to the to the VENDORS in respect of sale consideration of the SCHEDULE PROPERTY and Sri. B SURESH also paid the stamp duty and Reg. fees of Rs. 7,80,000/- on behalf of PURCHASER, which amount was originally paid by the PURCHASER to Sri. B. SURESH, the Consenting Witness; and”

12. The section 54 of the I.T.Act mandates that the assessee must invest in a new asset to be eligible for the claim of deduction under section 54 of the I.T.Act, i.e. within the periods specified in the Act, which in the instant case is not complied with. The assessee’s argument that the acquisition of the new asset by way of registration was not necessarily the determining factor, in so far as the contention that the capital gains was utilised within the specified time and the registration was not germane to the claim, as long as the asset was acquired.

13. The Hon’ble Apex Court in the case of Fibreboards (P) Ltd. v. CIT (2015) 376 ITR 596 (SC) had held that the utilization of the capital gains within the period would suffice for making the claim of deduction u/s 54G of the I.T.Act and there was no requirement to acquire the asset intended within the period specified, provided the same has been acquired in due course. The relevant observation of the Hon’ble Apex Court reads as follows:-

“36. A reading of Section 54G makes it clear that the assessee is given a window of three years after the date on which transfer has taken place to “purchase” new machinery or plant or “acquire” building or land. We find that the High Court has completely missed the window of three years given to the assessee to purchase or acquire machinery and building or land. This is why the expression used in 54G(2) is “which is not utilized by him for all or any of the purposes aforesaid….”. It is clear that for the assessment year in question all that is required for the assessee to avail of the exemption contained in the Section is to “utilize” the amount of capital gains for purchase and acquisition of new machinery or plant and building or land. It is undisputed that the entire amount claimed in the assessment year in question has been so “utilized” for purchase and/or acquisition of new machinery or plant and land or building.

37. The High Court is not correct when it states:-

“31. The word ‘purchase’ is not defined under the Act and therefore, has to be construed in the commercial sense. In many dictionaries, the word ‘purchase’ means the acquisition of property by party’s own act as distinguished from acquisition by act of law. In the context in which the expression issued by the Legislature requires first to be understood and interpretation that suits the context requires to be adopted. Exemption of capital gains under Section  54G of the Act can be claimed on transfer of assets in cases of shifting of industrial undertaking from urban area to any other non-urban area. This exemption may be claimed if the capital gains arising on transfer of any of assets of existing industrial unit is utilized within one year or three years after the date on which the transfer took place for purchase of new machinery or plant for the purposes of the business of the industrial undertaking in the area to which the said undertaking is shifted. The Legislature consciously has not used the expression ‘towards the purchase of plant and machinery’ as in Section 54(4) of the Act in contrast to Section  54(2) of the Act wherein the words ‘towards’ is used before the word ‘purchase’. The expression ‘purchased’ used in sub-clause (a) of section 54G of the Act requires to be understood as the domain and control given to the assessee. In the present case, it is not in dispute that the assessee has paid advance amount for acquisition of land, plant, building and machinery, etc., within the time stipulated in the Section, but it is not the case of the assessee that after such payment of advance amount, it has taken possession of land and building, plant and machinery. In our view, if the argument of the learned Senior Counsel for the assessee is accepted, it would defeat the very purpose and object of the Section itself. By merely paying some amount by way of advance towards the cost of acquisition of land for shifting its industrial unit from urban area to non-urban area, an assessee cannot claim exemption from payment of tax on capital gains. This cannot be the intention of the Legislature and an interpretation, which would defeat the very purpose, and the object of the Act requires to be avoided.” (at para 31 of the impugned judgment)

38. We are of the view that the aforesaid construction of Section 54G would render nugatory a vital part of the said Section so far as the assessee is concerned. Under sub-section (1), the assessee is given a period of three years after the date on which the transfer takes place to purchase new machinery or plant and acquire building or land or construct building for the purpose of his business in the said area. If the High Court is right, the assessee has to purchase and/or acquire machinery, plant, land and building within the same assessment year in which the transfer takes place. Further, the High Court has missed the key words “not utilized” in sub­section (2) which would show that it is enough that the capital gain made by the assessee should only be “utilized” by him in the assessment year in question for all or any of the purposes aforesaid, that is towards purchase and acquisition of plant and machinery, and land and building. Advances paid for the purpose of purchase and/or acquisition of the aforesaid assets would certainly amount to utilization by the assessee of the capital gains made by him for the purpose of purchasing and/or acquiring the aforesaid assets. We find therefore that on this ground also, the assessee is liable to succeed. The appeals are, accordingly, allowed and the judgment of the High Court is set aside.”

14. In the peculiar facts of the present case, the assessee has made advances to the developer, which has culminated in a purchase of a new residential house, sourced by the developer to fulfill his obligation of providing a residential house, which is also evidenced by the recitals in the sale deed, wherein he has affirmed the receipt of the advance and also paid for the new asset. The reliance placed by the assessee on the decision in the case of Sambandam Uday Kumar 345 ITR 389 [Karn], of the Jurisdictional High Court, is also relevant to facts of instant case. The Hon’ble jurisdictional High Court had held that amounts paid within the period of three years, would be eligible to the claim of deduction under section 54 of the I.T.Act, though the house was not registered within the period of three years or two years, considering the fact that the payment for the new asset was paid off within the specified time. The relevant finding of the Hon’ble High Court reads as follows:-

“14. In the instant case, the material on record discloses that the assessee had invested Rs.2,16,61,670/- as on 31.10.2006 within twelve months from the date of realization of sale proceeds of shares. The developer acknowledging the said amount has given particulars of the stage of construction. According to him, only minor fittings like window shutters and some electrical work were required to be made, In fact, the report of the inquiry conducted by the Department also discloses the flooring work, electrical work, fitting of door and window shutters were still pending. The assessee has produced before the authorities the registered sole deed dated 7.11.2009 showing the transfer of the property in his favour. The said document discloses marble tiles flooring has been done, electricity, water and sanitary connections have been given, wood used is teak in respect of doors and windows. The assessee has been put in possession of the property and he is in occupation. Therefore, the assessee has invested the sale consideration in acquiring a residential premises and has taken possession of the residential building and is living in the said premises. The object of enacting section 54 of the I.T.Act, i.e., to encourage investment in a residential building is completely fulfilled.”

15. It is also pretend to place reliance on the judgment of the Jurisdictional High Court in CIT Vs. Shakuntala Devi [2016] 389 ITR 366 (Kar), which has held that the investment in property if made within the time specified, the registration of the property though entered into beyond the period of three years. the assessee would be eligible for the claim of deduction under section 54 of the I.T.Act. The relevant finding of the Hon’ble jurisdictional High Court, reads as follows:-

“13. Facts on hand would disclose that assessee had owned a flat at Mumbai and sold the same on 04.02.2003 for a total consideration of Rs. 1,70,00,000/-. Subsequent to such sale she entered into an agreement for purchasing another property for a total consideration of Rs. 3,25,00,000/- by agreement dated 08.09.2003. Said agreement came to be entered into within six months from the date of sale i.e., 04.02.2003 and assessee had paid a total consideration of Rs.2,40,00,000/- between April’ 2003 to September’ 2003. After making the payment, a registered sale deed had not been executed in favour of the assessee before completion of two years period pursuant to Memorandum of Understanding dated 08.09.2003. The consideration received by her under sale dated 04.02.2003 has been paid by the assessee for purchasing another property and reinvestment has been made within two years as contemplated under Section 54 of the Act. These facts are not in dispute. Thus, long-term capital gains computed by virtue of sale deed stood adjusted by virtue of payment made by assessee for purchasing another property under Memorandum of Understanding dated 08.09.2003. As such, Tribunal has rightly held that date of purchase was to be taken as the basis for reckoning the period of two years prescribed under section 54 of the Act for extending the benefit flowing therefrom. In the instant case consideration paid by assessee under Memorandum of Understanding dated 08.09.2003 would fully cover the consideration of capital gains portion for being eligible to claim exemption under Section 54 of the Act.”

16. On the peculiar facts of the present case and considering the circumstances and evidences placed on record and considering the benevolent nature of section 54 of the I.T.Act read with the judicial pronouncements of the Supreme court and the jurisdictional High Court, cited supra, we are in agreement, that the utilisation of the capital gains within the time specified would entitle the assessee to the claim of deduction under section 54 of the Act, notwithstanding the fact that the new asset was registered beyond the period specified under the I.T.Act, which according to the assessee was beyond her control and was to be liberally construed. It is held by various Hon’ble Courts that application of beneficial provisions must be liberal to accommodate the rules laid down broadly to verify compliance and must not be interpreted literally, unlike charging sections which are to be construed strictly. In support of this proposition, we place reliance on the judgments of the Hon’ble Supreme Court in the case of Bajaj Tempo Ltd. v. CIT (1992) 196 ITR 188 (SC) and CIT v. Gwalior Rayon Silk Manufacturing Co. Ltd. (1992) 196 ITR 149 (SC).

17. As observed by us that the bonafides of the assessee cannot be doubted, since the assessee has made deposits into the capital gains scheme immediately and thereupon made payments to the developer to acquire the new house property. The assessee was also prevented by reasonable cause since the funds had already been utilized and was forced to acquire an asset due to the reason beyond her control. The section 54 of the I.T.Act being benevolent in nature, it should be liberal in interpreting the provisions of section 54 of the I.T.Act considering the fact that the new house was eventually acquired, out of the same capital gains utilized, which has been brought on record and not in dispute.

18. For the aforesaid reasoning, we hold that the assessee is entitled to the claim of deduction to the extent of Rs.1,26,00,000 and direct the A.O. to allow the claim u/s 54 of the I.T.Act to the said extent. Since we have held that the assessee is entitled to exemption u/s 54 of the I.T.Act in the peculiar set of facts, we do not deem it appropriate to adjudicate other grounds raised by the assessee in this appeal.

19. In the result, the appeal filed by the assessee is partly allowed.

Order pronounced on this 19th day of July, 2022.

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