HIRALAL K. JAIN Vs. INCOME TAX OFFICER

JUDGEMENT

(1.) This appeal filed by the assessee under Section 260A of the Income Tax Act, 1961 ('the Act' for brevity), is directed against the order dated 22.08.2012 passed by the Income Tax Appellate Tribunal, Madras "B" Bench, Chennai ('the Tribunal' for brevity) in I.T.A.No. 1201/Mds/ 2010 for the Assessment Year 2007-08. The above appeal was admitted on 25.04.2013 on the following Substantial Question of Law: ")Whether on the facts and circumstances of the case, the Appellate Tribunal was right in law in not adjudicating the claim that having invested the net consideration received as per the sale deed in a residential house the appellant is eligible for exemption under Section 54F in respect of the whole of the capital gains and for purposes of exemption under Section 54F full value of consideration should be read as referring to Section 48 only and not extended to Section 48 as modified by Section 50C?"

(2.) We have heard Mr.R.Kumar, learned counsel for the appellant/ assessee and Mr.T.R.Senthil Kumar, learned Senior Standing Counsel for the respondent/ Revenue.

(3.) It may not be necessary for this Court to decide the Substantial Questions of Law framed for consideration on account of certain subsequent developments. The Government of India enacted the Direct Tax Vivad Se Vishwas Act, 2020 (Act 3 of 2020) to provide for resolution of disputed tax and for matters connected therewith or incidental thereto. The Act of the Parliament received the assent of the President on 17th March 2020 and published in the Gazette of India on 17th March 2020.