Section 54F – Allotment date not relevant if Assessee made substantial payment for acquisition of new Flat

CA Sandeep Kanoi Moot point arising in the instant case, not addressed by the first appellate authority, i.e., as what constitutes a ‘purchase’ for the purposes of section 54F or, for that matter, the other para materia provisions. This is relevant as only upon ‘purchase’ could an assessee be said to have satisfied the qualifying condition of s. 54F(1), entitling it to exemption there-under. It would accordingly become relevant to determine whether the purchase of Flat B had taken place during the previous year relevant to AY 2008-09 or the current year, or, in short, the date of its p...