Exemption u/s 54EC is available in respect of investment made within six calendar months after the date of transfer not within 180 days: ITAT
In the case of Naresh Chand v/s ITO, Dehradun [ITA No. 3486/Del/2019], Delhi Tribunal held that exemption u/s 54EC is available in respect of investment made within six calendar months after the date of transfer not within 180 days.
Tribunal relied upon Hon’ble Coordinate Benches of the Mumbai Tribunal in the case of Neela S. Karyakarte vs. ITO (ITA No. 7548/Mum/2012, Aquatech Engineers vs. Addl. CIT (ITA No. 8029/Mum/2011 and NiamatMahroofVirji vs. ITO (ITA No. 1964/Mum/2014), wherein it was held that six months have to be interpreted as ‘six calendar months’ and not 180 days.
