S. 54EC investment time limit begins from date of receipt of consideration

Chanchal Kumar Sircar vs. ITO (ITAT Kolkota)

The assessee entered into an agreement and handed over possession to the buyer which constituted a “transfer”. The consideration received from the buyer was invested by the assessee in s. 54EC Bonds beyond 6 months from the date of transfer though within 6 months from the date of receipt of the consideration. The Tribunal had to consider whether in view of the language of s. 54EC that the consideration had to be invested in the specified bonds within 6 months of the date of transfer, the relief could be allowed. HELD by the Tribunal: