The assessee sold his residential flat at Malabar Hill for ₹43 crore and earned long-term capital gain of ₹26.59 crore. He invested in Flat No. 3102 at Lower Parel, Mumbai, and claimed exemption under section 54. He also earned long-term capital gain of ₹1.86 crore on sale of shares and claimed exemption under section 54F in respect of Flat No. 3101, which was initially purchased in the names of his wife and son. The Assessing Officer allowed exemption under section 54 only in respect of Flat No. 3102 and denied the section 54F claim on the ground that Flat No. 3101 stood in the names of the wife and son. The CIT(A), after admitting the registered Supplementary Agreement and bank statements and obtaining a remand report from the Assessing Officer, held that the two adjoining flats had subsequently been amalgamated into one composite residential flat, bearing Flat No. 3102. The assessee had made investment of ₹6.59 crore in Flat No. 3101 and the balance was paid by his wife; under the registered supplementary agreement, the assessee’s share in the composite flat was 70% and his wife’s share 30%. The Tribunal held that there was no violation of Rule 46A since the Assessing Officer was given an opportunity to examine the evidence and had furnished a remand report. On merits, the Tribunal noted that after amalgamation, Flat No. 3101 had lost its independent identity; the composite flat had a single entry and kitchen, its carpet area was 6,769 sq. ft., and the assessee had paid additional stamp duty on the increased area. Since the registered supplementary agreement established the amalgamation and the assessee’s investment, the Tribunal upheld the CIT(A)’s finding that the assessee was entitled to exemption of ₹26.59 crore under section 54 and ₹1.86 crore under section 54F. Revenue’s appeal dismissed.  (AY. 2021 -22 )  (ITA No. 599/Mum/2026 dt . 17 -8 -2026 )