JUDGMENT judgment of court was delivered by R. Sudhakar J.-This tax case (appeal) is filed by Revenue as against Income-tax Appellate Tribunal for assessment year 2007-08 raising following substantial questions of law: "1. Whether, on facts and in circumstances of case, Tribunal was justified in treating five independent flats in multistorey construction as single residential unit under section 54F without considering intention of Legislature to restrict reinvestment to only one more residential unit under section 54F? 2. Whether, on facts and in circumstances of case, Tribunal was right in interpreting phrase'a residential house' in plural connotation for purpose of reinvestment of capital gains for claiming exemption under section 54F?" brief facts are as follows: respondent-assessee had entered into agreement with one M/s. Mount Housing and Infrastructure Ltd. for development of piece of land measuring 13,059 sq. ft. owned by her at Door No. 29F, Race Course, Coimbatore. As per agreement, assessee was to receive 43.75 per cent. of built-up area after development. This 43.75 per cent. builtup area was translated into five flats. assessee, while filing her return of income, calculated capital gains based on sale consideration of Rs. 1,09,75,620. As per assessee, this was value of flats, which were to be received by her and was equivalent to 56.25 per cent. of undivided share of land given by her to M/s. Mount Housing and Infrastructure Ltd. assessee claimed exemption under section 54F of Income-tax Act on value of five flats. According to assessee, there were no capital gains whatsoever left for assessment. Before Assessing Officer, two issues were raised, one on value of built-up area of five flats and other was whether assessee would be entitled to benefit of section 54F of Income-tax Act in respect of five flats. Assessing Officer granted benefit of capital gains in respect of one flat and that too on higher extent with regard to floor space, viz., 2413.36 sq. ft. Aggrieved by same, assessee preferred appeal before Commissioner of Income-tax (Appeals). Commissioner of Income-tax (Appeals), by order dated May 6, 2010, after discussing provisions of sections 54 and 54F of Incometax Act, held that claim of assessee under section 54F for all five flats could not be admitted but, however, he took view that assessee would be entitled to benefit of section 54F in respect of one single flat with largest area of 4814.36 sq. ft. and, accordingly, directed Assessing Officer to calculate exemption under section 54F of Income-tax Act. Aggrieved by this order, assessee preferred further appeal before Income-tax Appellate Tribunal. Tribunal, after considering orders of authorities below, held in paragraph 4 of order that as assessee's representative admitted that with regard to substitution of sale consideration based on cost of construction of developer, M/s. Mount Housing and Infrastructure Ltd., order of Commissioner of Income-tax (Appeals) could not be faulted. Also, Tribunal, by considering provision of section 54F of Income-tax Act and taking note of decision of Karnataka High Court in case of CIT v. Smt. K. G. Rukminiamma reported in [2011] 331 ITR 211 (Karn), which referred to section 13 of General Clauses Act, 1897, held that word "a" appearing in section 54F of Incometax Act should not be construed in singular but should be understood in plural. Hence, following said decision of Karnataka High Court, Tribunal held as follows: "Their Lordships has clearly held in above judgment that'residential house' in context could not be construed as singular. In said case also, claim for exemption was with regard to four flats in lieu of share in land but claim was under section 54 of Act and not under section 54F of Act. However, in our opinion, meaning given to expression'a residential house' will apply pari passu to section 54F also since expression used here is also'a residential house'. New asset defined in section 54F, as'a residential house' has also to be understood in plural. It is not necessary that all residential units should have single door number allotted to it as argued by learned Departmental representative. No doubt hon'ble jurisdictional High Court in case of G. Saroja (supra) did consider fact that different flats were having one door number. However, this alone was not reason why assessee was held to be eligible for claiming of exemption under section 54F of Act. Their Lordships took cue from decision of hon'ble Karnataka High Court in case of Smt. K. G. Rukminiamma (supra). Similar exemption was given by hon'ble jurisdictional High Court again in case of Smt. Dr. P. K. Vasanthi Rangarajan (supra) wherein there was no claim that flats allotted in lieu were having single number. We are, therefore, of opinion that assessee was eligible for claiming exemption under section 54F of Act on five flats received by her in lieu of land she had parted with." Tribunal further held that principles mentioned in section 54 of Income-tax Act, as interpreted by Karnataka High Court in abovesaid decision, would apply pari passu to section 54F also. Hence, Tribunal came to conclusion that assessee was eligible for exemption under section 54F of Income-tax Act on five flats received by her in lieu of land she had parted with. Aggrieved by this order of Tribunal, Revenue has preferred present appeal raising abovesaid substantial questions of law. Learned counsel appearing for Revenue submits that residential house mentioned in section 54F of Income-tax Act should not be construed as one unit even though different flats are constructed but it should be construed as one residential flat, as every residential apartment contains separate kitchen, entrance, etc. He also pointed out to amendment brought to section 54F of Income-tax Act, vide Finance (No. 2) Act, 2014, with effect from April 1, 2015, wherein words "a residential house" is substituted to "one residential house". Hence, assessee is not eligible for exemption under section 54F of Income-tax Act. We have heard learned standing counsel appearing for Revenue at length and perused materials placed before this court and decision relied on by Tribunal in case of CIT v. Smt. K. G. Rukminiamma reported in [2011] 331 ITR 211 (Karn). We find that relevant provision in this case is section 54F of Income-tax Act, which reads as follows: "54F. Capital gain on transfer of certain capital assets not to be charged in case of investment in residential house.-(1) Subject to provisions of sub- section (4), where, in case of assessee being individual or Hindu undivided family, capital gain arises from transfer of any long-term capital asset, not being residential house (hereafter in this section referred to as original asset), and assessee has, within period of one year before or two years after date on which transfer took place purchased, or has within period of three years after that date constructed, residential house (hereafter in this section referred to as new asset), capital gain shall be dealt with in accordance with following provisions of this section, that is to say,- (a) if cost of new asset is not less than net consideration in respect of original asset, whole of such capital gain shall not be charged under section 45; (b) if cost of new asset is less than net consideration in respect of original asset, so much of capital gain as bears to whole of capital gain same proportion as cost of new asset bears to net consideration, shall not be charged under section 45: Provided that nothing contained in this sub-section shall apply where- (a) assessee,- (i) owns more than one residential house, other than new asset, on date of transfer of original asset; or (ii) purchases any residential house, other than new asset, within period of one year after date of transfer of original asset; or (iii) constructs any residential house, other than new asset, within period of three years after date of transfer of original asset; and (b) income from such residential house, other than one residential house owned on date of transfer of original asset, is chargeable under head'Income from house property'." It is relevant to note herein that amendment was made to abovesaid provision with regard to word "a" by Finance (No. 2) Act, 2014, which will come into effect from April 1, 2015. said amendment reads as follows: "32a. Words'constructed , one residential house in India' shall be substituted for'constructed, residential house' by Finance (No. 2) Act, 2014, with effect from April 1, 2015." abovesaid amendment to section 54F of Income-tax Act, which will come into effect only from April 1, 2015, makes it very clear that benefit of section 54F of Income-tax Act will be applicable to constructed one residential house in India and that clarifies situation in present case, i.e, post-amendment, viz., from April 1, 2015, benefit of section 54F will be applicable to one residential house in India. Prior to said amendment, it is clear that residential house would include multiple flats/residential units as in present case where assessee has got five residential flats. We may also mention here that all authorities below have clearly understood that agreement signed by assessee with M/s. Mount Housing Infrastructure Ltd., is that assessee will receive 43.75 per cent. of built-up area after development, which is construed as one block, which may be one or more flats. In that view of matter what was before Assessing Officer is only equivalent of 56.25 per cent. of land transferred, equivalent to 43.75 per cent. of built-up area received by assessee. This built-up area got translated into five flats. Hence, we are of opinion that transaction in this case was not with regard to number of flats but with regard to percentage of builtup area vis-a-vis undivided share of land. In similar circumstances, this court, by order dated January 4, 2012, in T. C. (A.) No. 656 of 2005 held as follows: "The above provision refers to residential house meaning thereby that even if there are four different flats and if it is considered for property assessed as one unit and one door number is given, it should be construed as residential unit, namely, one unit. In that sense, said provision is available to assessee." In decision reported in Smt. Dr. P. K. Vasanthi Rangarajan [2012] 75 DTR 56, this court, while dealing with benefit of exemption under section 54F, followed abovesaid decision of this court in T. C. (A.) No. 656 of 2005 and granted benefit to assessee under section 54F of Income-tax Act on investment made in four flats. Hence, abovesaid decisions of this court make it clear that property should be assessed as one unit even though different flats are available. Here also, as per assessment order, all flats have one door number, namely, Door No. 29F, Race Course, Coimbatore. In light of above, we find no question of law much less any substantial question of law arises for consideration in this tax case (appeal). Accordingly, this tax case (appeal) stands dismissed. No costs. *** Commissioner of Income-tax v. Smt. V. R. Karpagam