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    <title>2016 (7) TMI 275 - ITAT AHMEDABAD</title>
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    <description>The Tribunal allowed the appeal, directing the Assessing Officer to delete the addition of deemed income under Section 50C of the Income Tax Act. It was held that as only rights were transferred, not the land itself, Section 50C was deemed inapplicable. The Tribunal also ruled that Circular No. 549 issued by CBDT was ultra vires, stating that Assessing Officers are not bound by such circulars. The judgment clarified the necessity for a transfer of a capital asset like land or building for Section 50C to apply.</description>
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      <link>https://www.taxtmi.com/caselaws?id=329677</link>
      <description>The Tribunal allowed the appeal, directing the Assessing Officer to delete the addition of deemed income under Section 50C of the Income Tax Act. It was held that as only rights were transferred, not the land itself, Section 50C was deemed inapplicable. The Tribunal also ruled that Circular No. 549 issued by CBDT was ultra vires, stating that Assessing Officers are not bound by such circulars. The judgment clarified the necessity for a transfer of a capital asset like land or building for Section 50C to apply.</description>
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