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Mar 16, 2026
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Taxpayer sells one house and buys 7 flats with capital gains. Tax dept denies benefit — here’s what ITAT rules
In a significant ruling that could influence how capital gains tax exemptions are interpreted, the Delhi bench of the Income Tax Appellate Tribunal (ITAT) has held that multiple adjacent residential units can be treated as a single “residential house” for claiming exemption under Section 54 of the Income-tax Act.
The decision came in the case of Saroj Rani vs ITO (ITA No. 5472/DEL/2024) and deals with a long-running debate over whether investing in more than one apartment can still qualify for the capital gains exemption meant for investment in “one residential house”.
The background: Sale of property and reinvestment
The dispute arose after taxpayer Saroj Rani sold a residential property in Punjabi Bagh, Delhi for about Rs 2.70 crore and claimed exemption under Section 54 by reinvesting the proceeds into another residential property.
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