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Assessee has raised the ground that the learned Commissioner of Income Tax (Appeals) erred in confirming action of the Assessing Officer of disallowing claim for exemption u/s. 54EC amounting to Rs. 50,00,000/-.

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Sec. 54EC of Income Tax Act, 1961— Capital gain —There is no distinction between the transfer of title and the completion of sale; and the title passes only when the document is registered under the Registration Act and the mere fact that such transfer operates from the date of execution is not sufficient to conclude that the title itself passes on the date of execution, consequently, the transfer in the case of assessee could not be deemed to have been expected on the date of execution of the document- Assessee eligible for exemption under section 54EC as assessee invested the LTCG in NHAI bond within six month of transfer of asset - CHANDRAVADAN C. PITHAWALLA V/s ITO - [2020] 27 ITCD Online 073 (ITAT-MUMBAI)