Capital Gain Dispute: Section 50C Adjustment Contested Due to Valuation Discrepancy; Statutory Amendment Considered Retrospective.

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....Capital gain computation - addition u/s. 50C of the Act on account of difference in the value adopted by the DVO and the sale consideration - The incongruity in the statute was glaring and undue hardship not in dispute. Once it is not in dispute that a statutory amendment is being made to remove an undue hardship to the assessee or to remove an apparent incongruity, such an amendment has to be treated as retrospective, effective from the date on which the law, containing such an undue hardship or incongruity, was introduced. - AT....