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Section 50 is a special computational provision for gains on transfer of depreciable assets, and its deeming fiction cannot be extended beyond that limited purpose. Although the gain is treated as short-term for computation, the underlying asset does not lose its long-term character. For section 74 set-off, the relevant test is the actual nature of the asset transferred, so long-term capital losses could be adjusted against the gain computed under section 50. The appellate order allowing set-off of current-year and brought-forward long-term capital losses was upheld, and the Revenue's appeal was dismissed.
Section 50 is a special computational provision for gains on transfer of depreciable assets, and its deeming fiction cannot be extended beyond that limited purpose. Although the gain is treated as short-term for computation, the underlying asset does not lose its long-term character. For section 74 set-off, the relevant test is the actual nature of the asset transferred, so long-term capital losses could be adjusted against the gain computed under section 50. The appellate order allowing set-off of current-year and brought-forward long-term capital losses was upheld, and the Revenue's appeal was dismissed.
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