The law
Income-tax Act 1961, Sec 54EC(1) (now Sec 85)
Long-term gain from land or building or both is exempt to the extent invested within 6 months of transfer in a long-term specified asset; proportionate if less than the gainSource
Income-tax Act 1961, Sec 54EC(1) (now Sec 85) provisos
Investment in such bonds cannot exceed ₹50 lakh in a financial year, and ₹50 lakh in total across the year of transfer and the next yearSource
Income-tax Act 1961, Sec 54EC (now Sec 85) Explanation (b)
For investments from 1 April 2018: bonds issued on or after that date, redeemable after 5 years, by NHAI, REC or other notified issuersSource
CBDT Notification No. 31/2025 dated 7 April 2025
HUDCO bonds redeemable after 5 years notified as a long-term specified assetSource
Income-tax Act 1961, Sec 54EC(2) (now Sec 85)
If the bond is transferred or converted into money within 5 years, or a loan is taken against it, the exempted gain is taxed in that yearSource
Income-tax Act 1961, Sec 54EC(3) (now Sec 85)
Cost of the bonds cannot also be claimed under Sec 123 (old Sec 80C)Source
Income-tax Act 2025, Sec 85 (corresponds to old Sec 54EC)
From tax year 2026-27; practitioner view that the new wording ('long-term capital gains' from land or building) may exclude gains on depreciable buildings deemed short term under Sec 74Source
Income-tax Act 1961 to 2025 mapping
Old Sec 54EC corresponds to new Sec 85Source
Government fee
No government fee. Bonds are bought at issue price from the issuer; interest is taxable each year. Tax on any gain above the invested amount at 12.5% (or 20% indexed for residents with property bought before 23 July 2024). Source: https://incometaxindia.gov.in/Tutorials/15-%20LTCG.pdf
Late fee or penalty
No extension in the Act: investment after 6 months loses the exemption, although a tribunal excused delay where bonds were not available. Source: https://www.taxmanagementindia.com/web/tmi_blog_details.asp?id=361219 . Late return fee under Sec 428 (old Sec 234F). Source: https://www.incometaxindia.gov.in/w/section-234f