Assessment u/s 147 Valid: Sale Consideration Taxed as Capital Gains, Not Section 56. Related Property Dispute.

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....Validity of the assessment proceedings initiated u/s 147 - the assessee has shown the sale consideration under the head capital gain and the amount in dispute directly relates to the same property and therefore the same can only be brought to tax under the head capital gain. In other words, the same cannot be made subject to the tax under the provisions of section 56 - AT....