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Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether Section 50C of the Income-tax Act, 1961 applies to a purchaser of immovable property.
Analysis: The provision was examined on its plain terms and found to operate in relation to the transferor or seller of a capital asset, where consideration received or deemed consideration is brought to tax. It does not extend to a purchaser who has acquired the property. The stamp duty valuation relied upon by the Department could not enlarge the statutory scope of the provision beyond its text.
Conclusion: Section 50C could not be invoked against the assessee as purchaser, and the challenge to the Tribunal's decision failed.
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