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JUDGMENT R. Sudhakar, J. - The Revenue is the appellant in these appeals. While T.C.(A) No.419 of 2014 is filed challenging the order of the Income Tax Appellate Tribunal 'B' Bench, Chennai, dated 1.11.2013 made in I.T.A.No.456/Mds/2013 for the assessment year 2009-2010, T.C.(A).No.533 of 2014 is filed challenging the order of the Income Tax Appellate Tribunal 'D' Bench, Chennai, dated 31.1.2013 made in I.T.A.No.1950/Mds/2012 for the assessment year 2008-2009. 2. These appeals were admitted on the following substantial questions of law: "(i) Whether on the facts and circumstances of the case, the Tribunal was right in holding that the assessee is eligible for deduction of Rs.1 Crore under Section 54EC, in respect of investment of Rs.50 Lakhs made in two different financial years? (ii) Whether on the facts and circumstances of the case, the Tribunal was right in not referring the matter to the Special Bench under Section 255(4), when there are conflicting views by different benches?" 3.1 For better clarity, we state the facts of the case in T.C.(A) No.533 of 2014. The assessee filed return of income on 27.9.2009 and the same was processed under Section 143(1) of the Act. The case of the assessee was selected for scrutiny and notices under Sections 143(2) and 142(1) of the Income Tax Act, 1961 (for brevity, "the Act") were issued on 29.9.2010 and 14.10.2010 respectively. In terms of the said notice, the assessee furnished details to the department. 3.2 It is stated that the assessee sold a property at Palavakkam for a sale consideration of Rs.3,46,50,000/- vide agreement of sale dated 18.2.2008 entered into with the Ceebros Property Developments. The appellant invested Rs.1,00,00,000/- out of the sale proceeds in certain bonds in two financial years, namely, Rs.50,00,000/- in Rural Electrification Corporation Bonds in the financial year 2007-2008 and Rs.50,00,000/- in National Highways HAI Bond in the financial year 2008-2009. 3.3 The Assessing Officer held that the assessee can take the benefit of investment in specified bonds to a maximum of Rs.50,00,000/- only under Section 54EC(1) of the Act and accordingly, held that the other sum Rs.50,00,000/- invested…

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