Section 50C and tenancy rights: transfer of tenancy rights falls outside the provision, with no substantial question of law arising.

Section 50C of the Income-tax Act was considered in relation to transfer of tenancy rights, and the Tribunal's view was that such transfer does not amount to transfer of land, building or both and therefore falls outside the section. That approach followed its earlier decision in Shri Atul G. Puranik, which the Revenue had already accepted. On that basis, the Revenue's proposed questions did not raise any substantial question of law for consideration.

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Issues: Whether Section 50C of the Income-tax Act, 1961 applies to transfer of tenancy rights, and whether any substantial question of law arose for consideration.

Analysis: The Tribunal had held that transfer of tenancy rights does not amount to transfer of land or building or both and therefore falls outside the scope of Section 50C. That view was based on its earlier decision in Shri Atul G. Puranik, which had already been accepted by the Revenue. In that background, the questions proposed by the Revenue did not give rise to any substantial question of law.

Conclusion: Section 50C was held inapplicable to transfer of tenancy rights, and the appeal was dismissed.

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