CIT's Section 263 revision on capital gains computation overturned; AO's assessment deemed correct as per Section 50C.

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....Revision u/s 263 by CIT - Wrong Capital gain computation as AO not examined the transaction by the angle of section 50C - in our considered view the view taken by the AO in accepting the capital gain/loss on capital contribution of (03)three pieces of land is not erroneous. Therefore, the twin condition as enunciated under section 263 of the Act is not made out in the present case, thus, the order passed by the ld. PCIT is set-aside - AT....