Assessee allowed Deduction U/s. 54 depsite non completion of construction within 3 years

In the present case, the assessee had already appropriated the capital gains for the purpose of construction of residential unit. However, construction was not completed within the stipulated period. In our opinion, liberal interpretation to be considered while granting exemption under section 54 of the Act as it is a beneficial provision. The judgment of Karnataka High Court in the case of CIT v. Smt. V.S. Shantha Kumari in 126 DTR 436(Kar.) wherein held that completion of construction within three years was not mandatory and was necessary

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