you have raised a nice point. I will try to express my views in this manner (1) if we go by the special bench decision of sushila zhaveri, the letter "a" has to be given precise meaning i.e. one. similar letter "a" is used with the pharase long term asset (asset transferred) in section 54. Logically, in that case reply should be in negative. (2) however, if both units which are transferred constitute one residential unit, the exemption can be claimed as per the logic of K.G. rukminiamma. (3) there appears to be a distinction in section 54 & section 54F in respect of transferred asset. section 54 uses the letter "a" whereas section 54F uses the word "any". Hence, the logic of mutiple assets sold and one new asset purchased may not be correct as far as section 54 is concerned. (4) in the recent mumbai tribunal decision of rajiv pillai, one to one relation is mentioned. That also leads to believe that for two different residential houses, one new asset can not be purchased. There should be two against two. (5) finally, if one looks at the very objective of section 54 i.e. promotion of housing, it appears that purchase of one house against two or more houses does not adversely affect the objective. Hence, it should be allowed. I am in the process of fsearching for any direct decision in the matter, If i find, i will surely post it.