Section 50C does not extend to transfer of tenancy rights, as the deeming fiction is confined to land or building.

Section 50C is a deeming provision confined to transfers of land, building or both, and it cannot be extended by analogy to cover tenancy rights. Because tenancy rights are distinct from land or building, their transfer falls outside the statutory ambit of section 50C. The Revenue's challenge therefore fails on this issue.

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Issues: Whether section 50C of the Income-tax Act, 1961 applies to the transfer of tenancy rights.

Analysis: Section 50C is a deeming provision that substitutes the stamp valuation authority's value only in respect of capital assets described as land or building or both. Tenancy rights are distinct from land or building and cannot be brought within that expression by extension or extrapolation of the deeming fiction. The transfer in question therefore falls outside the ambit of section 50C.

Conclusion: Section 50C does not apply to the transfer of tenancy rights, and the Revenue's grounds fail.

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