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    <title>2026 (5) TMI 719 - ITAT BANGALORE</title>
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    <description>Section 50C applies only to transfers of capital assets for capital gains computation and does not govern sites held as stock in trade or business inventory. The Tribunal therefore required factual verification of the assessee&#039;s claim that the sites were part of a real estate business, with the Assessing Officer directed to examine books of account, land records and supporting material afresh. Because the quantum issue was restored for de novo consideration, the connected penalty proceedings under sections 271D and 271(1)(c) were also remitted for fresh decision after reasonable opportunity to the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791517</link>
      <description>Section 50C applies only to transfers of capital assets for capital gains computation and does not govern sites held as stock in trade or business inventory. The Tribunal therefore required factual verification of the assessee&#039;s claim that the sites were part of a real estate business, with the Assessing Officer directed to examine books of account, land records and supporting material afresh. Because the quantum issue was restored for de novo consideration, the connected penalty proceedings under sections 271D and 271(1)(c) were also remitted for fresh decision after reasonable opportunity to the assessee.</description>
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