JUDGMENT judgment of court was delivered by R. Sudhakar J.-The Revenue has filed this appeal challenging order of Income-tax Appellate Tribunal "B" Bench, Chennai, dated June 25, 2013, made in I. T. A. No. 411/Mds/2013 for assessment year 2009-10, by raising following questions of law: "(i) Whether Tribunal was right in relying upon decision of Sriram Indubal v. ITO in I. T. A. No. 1950/Mds/2012, especially when there is appeal pending before High Court which has been preferred by appellant? (ii) Whether Tribunal ought to have noted that intention of Legislature is to limit investment in long-term specified asset to Rs. 50 lakhs as held in case of Areva T and D India Ltd. v. Asst. CIT [2010] 326 ITR 540 (Mad), which had been relied upon by Assessing Officer and Commissioner of Income-tax (Appeals)?" 2.1. brief facts of case are as under: assessee-company is engaged in business of manufacturing engineering components and offering engineering consultancy. assessee-company filed return of income for assessment year 2009-10 admitting taxable income of Rs. 67,68,507. return was selected for scrutiny and notice under section 143(2) of Income- tax Act was issued on August 20, 2010. Subsequently, after obtaining copies of returns of income and other relevant documents, notice under section 142(1) of Act was issued on July 14, 2011. assessee furnished such details on October 9, 2011, and October 19, 2011. 2.2. It was noticed from documents filed by assessee that assessee sold land and building of Hyderabad unit for total consideration of Rs. 1,75,00,000. assessee claimed to have sold land component at Hyderabad for Rs. 1,13,74,000 and after adjusting indexed cost of acquisition, total long-term capital gains was calculated at Rs. 1,09,98,256, of which Rs. 1,00,00,000 was claimed as deduction under section 54EC of Act, by investing Rs. 50 lakhs in REC Bonds on March 31, 2009, and another Rs. 50 lakhs in REC Bonds on April 31, 2009. However, Assessing Officer restricted deduction to Rs. 50 lakhs by stating that intention of Legislature is to limit investment in longterm specified asset to Rs. 50 lakhs only, by placing reliance on decision of this court in Areva T and D India Ltd. v. Assistant CIT [2010] 326 ITR 540 (Mad). 2.3. Aggrieved by said order, assessee preferred appeal before Commissioner of Income-tax (Appeals), who confirmed order passed by Assessing Officer. 2.4. Calling into question said order, assessee preferred appeal to Tribunal. Tribunal held that exemption granted under proviso to section 54EC(1) of Act should be construed not transaction-wise but financial year-wise. It further held that if assessee is able to invest sum of Rs. 50,00,000 each in two different financial years, within period of six months from date of transfer of capital asset, it cannot be said to be inadmissible. Accordingly, Tribunal allowed appeal filed by assessee. 2.5. Assailing said order passed by Tribunal, Revenue has filed this appeal on questions of law referred supra. We have heard Mr. T. Ravi Kumar, learned senior standing counsel appearing for Revenue and Mr. Venkat Narayanan, learned counsel appearing for respondent. issue involved in this appeal is no longer res integra in view of decision of this court in CIT v. C. Jaichander (order dated September 15, 2014, made in T. C. (A.) Nos. 419 and 533 of 2014-[2015] 370 ITR 579 (Mad), to which one of us-R. Sudhakar J. is party). In said decision, this court held as under (page 583): "The key issue that arises for consideration is whether first proviso to section 54EC(1) of Act would restrict benefit of investment of capital gains in bonds to that financial year during which property was sold or it applies to any financial year during six months period. For better understanding of issue, it would be apposite to refer to section 54EC(1) of Act, which reads as under: section 54EC(1) of Act, which reads as under: '54EC. Capital gain not to be charged on investment in certain bonds.-(1) Where capital gain arises from transfer of longterm capital asset (the capital asset so transferred being hereafter in this section referred to as original asset) and assessee has, at any time within period of six months after date of such transfer, invested whole or any part of capital gains in long-term specified asset, capital gain shall be dealt with in accordance with following provisions of this section, that is to say,- (a) if cost of long-term specified asset is not less than capital gain arising from transfer of original asset, whole of such capital gain shall not be charged under section 45; (b) if cost of long-term specified asset is less than capital gain arising from transfer of original asset, so much of capital gain as bears to whole of capital gain same proportion as cost of acquisition of long-term specified asset bears to whole of capital gain, shall not be charged under section 45: Provided that investment made on or after 1st day of April, 2007, in long-term specified asset by assessee during any financial year does not exceed fifty lakh rupees.' On plain reading of above said provision, we are of view that section 54EC(1) of Act restricts time limit for period of investment after property has been sold to six months. There is no cap on investment to be made in bonds. first proviso to section 54EC(1) of Act specifies quantum of investment and it states that investment so made on or after April 1, 2007, in longterm specified asset by assessee during any financial year does not exceed fifty lakhs rupees. In other words, as per mandate of section 54EC(1) of Act, time limit for investment is six months and benefit that flows from first proviso is that if assessee makes investment of Rs. 50,00,000 in any financial year, it would have benefit of section 54EC(1) of Act. Legislature noticing ambiguity in abovesaid provision, by Finance (No. 2) Act, 2014, with effect from April 1, 2015, inserted after existing proviso to sub-section (1) of section 54EC of Act, second proviso, which reads as under: 'Provided further that investment made by assessee in long-term specified asset, from capital gains arising from transfer of one or more original assets, during financial year in which original asset or assets are transferred and in subsequent financial year does not exceed fifty lakhs rupees.' At this juncture, for better clarity, it would be appropriate to refer to Notes on Clauses-Finance (No. 2) Bill, 2014, and Memorandum Explaining Provisions in Finance (No. 2) Bill, 2014, which read as under (see [2014] 365 ITR (St.) 103, 120): 'Notes on Clauses-Finance (No. 2) Bill, 2014: Clause 23 of Bill seeks to amend section 54EC of Incometax Act relating to capital gain not to be charged on investment in certain bonds. existing provisions contained in sub-section (1) of section 54EC provide that where capital gain arises from transfer of long-term capital asset and assessee has within period of six months invested whole or part of capital gains in long-term specified asset, proportionate capital gains so invested in long-term specified asset out of total capital gains shall not be charged to tax. proviso to said sub-section provides that investment made in long-term specified asset during any financial year shall not exceed fifty lakhs rupees. It is proposed to insert proviso below first proviso in said subsection (1) so as to provide that investment made by assessee in long-term specified asset, from capital gains arising from transfer of one or more original assets, during financial year in which original asset or assets are transferred and in subsequent financial year does not exceed fifty lakh rupees. This amendment will take effect from 1st April, 2015 and will, accordingly, This amendment will take effect from 1st April, 2015 and will, accordingly, apply in relation to assessment year 2015-16 and subsequent years. Memorandum explaining provisions in Finance (No. 2) Bill, 2014 (see [2014] 365 ITR (St.) 149, 184): Capital gains exemption on investment in specified bonds. existing provisions contained in sub-section (1) of section 54EC of Act provide that where capital gain arises from transfer of long-term capital asset and assessee has, within period of six months, invested whole or part of capital gains in longterm specified asset, proportionate capital gains so invested in long-term specified asset, out of whole of capital gain, shall not be charged to tax. proviso to said sub-section provides that investment made in long-term specified asset during any financial year shall not exceed fifty lakhs rupees. However, wordings of proviso have created ambiguity. As result capital gains arising during year after month of September were invested in specified asset in such manner so as to split investment in two years i.e., one within year and second in next year but before expiry of six months. This resulted in claim for relief of one crore rupees as against intended limit for relief of fifty lakhs rupees. Accordingly, it is proposed to insert proviso in sub-section (1) so as to provide that investment made by assessee in longterm specified asset, out of capital gains arising from transfer of one or more original asset, during financial year in which original asset or assets are transferred and in subsequent financial year does not exceed fifty lakh rupees. This amendment will take effect from 1st April, 2015 and will, accordingly, apply in relation to assessment year 2015-16 and subsequent assessment years.' Legislature has chosen to remove ambiguity in proviso to section 54EC(1) of Act by inserting second proviso with effect from April 1, 2015. memorandum explaining provisions in Finance (No. 2) Bill, 2014, also states that same will be applicable from April 1, 2015, in relation to assessment year 2015-16 and subsequent years. intention of Legislature probably appears to be that this amendment should be for assessment year 20152016 to avoid unwanted litigations of previous years. Even otherwise, we do not wish to read anything more into first proviso to section 54EC(1) of Act, as it stood in relation to assessees. In any event, from reading of section 54EC(1) and first proviso, it is clear that time limit for investment is six months from date of transfer and even if such investment falls under two financial years, benefit claimed by assessee cannot be denied. It would have made difference, if restriction on investment in bonds to Rs. 50,00,000 is incorporated in section 54EC(1) of Act itself. However, ambiguity has been removed by Legislature with effect from April 1, 2015, in relation to assessment year 2015-16 and subsequent years. For foregoing reasons, we find no infirmity in orders passed by Tribunal warranting interference by this court. substantial questions of law are answered against Revenue and these appeals are dismissed." (emphasis supplied) decision of this court in Areva T and D India Ltd. v. Asst. CIT [2010] 326 ITR 540 (Mad), relied upon by learned senior standing counsel for appellant is not applicable to facts of present case, as in said decision writ petitions filed "for issuance of writ of declaration declaring that conditions occurring in Notification No. 380 of 2006 (F. No. 142/09/ 2006- TPL, dated December 22, 2006 (see [2007] 288 ITR (St.) 6)), along with words "subject to following conditions, namely," issued by Central Board of Direct Taxes are ultra vires section 54EC of Income-tax Act, 1961, and arbitrary and violative of articles 14 and 265 of Constitution of India and, consequently, unenforceable", were dismissed as infructuous taking note of subsequent amendment to section 54EC of Act incorporating limit on amount of investment in bonds in section itself. For reasons aforesaid, we do not find any question of law, much less substantial question of law that arises for our consideration in this appeal. Accordingly, this appeal is dismissed. No costs. *** Commissioner of Income-tax v. Coromandel Industries Ltd.