Per Shri Manzoor Ahmed Bakhshi J.M.- These two appeals of the assessee relating to assessment years 1992-93 and 1993-94, involving common issue, are disposed of by this consolidated order. The issue involved is relating to exemption claimed under section 54F of the Income-tax Act, 1961 out of the capital gains derived by the assessee in the aforementioned assessment years. Relevant facts are that assessee had sold certain shares in March 1992 in consideration of Rs. 21,71,680. Since the cost of the shares was Rs. 23,000 only, the capital gain on the sale of shares was Rs. 21,48,680. Assessee had purchased a house property in New Friends Colony jointly with her daughter Mrs. Ushmi Sethi in July 1992 in consideration of Rs. 80 lacs. The investment had been made by the two owners as under:

Assessee has met the consideration from the sale of shares and jewellery. The capital gains on the sale of shares had been disclosed by the assessee in assessment year 1992-93 as well as in assessment year 1993-94. However, benefit under section 54F was claimed in respect of the entire capita