Thje Kerala High Court in the case of ITO v. K.C. Gopalan (107TAXC591) held that there is no restriction under the law that the sale consideration itself should be utilized by the assessee for the purchase or construction of the new house property. In other words one can use any other source for this purpose. The Court interpreted the law under sections 53/54 to hold that a special provision is made in respect of capital gains arising out of transfer of particular type of capital asset, namely, house property, which was being used by the assessee or a parent of his for the purpose of their residence.