Case Law Details
Velayutham Surya Narayanan Vs ITO (ITAT Chennai)
In the case of Velayutham Surya Narayanan Vs ITO (ITAT Chennai) for Assessment Year 2016-17, the issue revolved around the denial of deduction under Section 54F of the Income Tax Act. The assessee had reinvested proceeds from the sale of property in a residential property purchased in his wife’s name. The Assessing Officer (AO) and the Commissioner of Income Tax (Appeals) (CIT(A)) denied the deduction, arguing that the investment wasn’t made directly by the assessee and did not meet statutory requirements.
The Tribunal considered arguments from both sides. It acknowledged that while the property was indeed purchased in the wife’s name using a bank loan, the assessee had contributed significantly towards the purchase and construction costs. The Tribunal emphasized that Section 54F doesn’t explicitly require reinvestment from the sale proceeds alone and that liberal interpretation should be applied to such beneficial provisions. They cited precedents supporting deductions in cases where investments were made jointly or in the name of family members.
Ultimately, the Tribunal ruled in favor of the assessee, directing the AO to allow the deduction under Section 54F. They highlighted the common financial interest between the assessee and his wife in making the investment. The decision was based on the principle that statutory provisions should be interpreted liberally to fulfill their intended purpose.
FULL TEXT OF THE ORDER OF ITAT CHENNAI
Please become a Premium member. If you are already a Premium member, login here to access the full content.
Author Bio
