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2021 (1) TMI 793 - HC - Income TaxRevision u/s 264 - revised capital gain u/s 50C of the Act - writ applicant submit that he is confining his case only to Section 50C as according to him Principal Commissioner has not recorded any finding, as regards Section 50C of the Act and for this limited purpose, the matter may be remitted so that the issue of Section 50C can be considered - HELD THAT:- For the forgoing reasons, this writ application succeeds in part. The impugned order passed by the Principal Commissioner, Ahmedabad dated 19th March, 2018, Annexure – H to this writ application, is hereby quashed and set aside. The matter is remitted to the Principal Commissioner of Income Tax-4, Ahmedabad for the purpose of adjudicating the issue with regard to Section 50C of the Act. At this stage, we may once clarify again so that there may not be any confusion in future that the issue with regard to limitation stands concluded. The issue with regard to limitation shall not be re-opened by the Principal Commissioner while adjudicating the claim of the writ applicant with respect to Section 50C of the Act. In this regard, we clarify that we have not expressed any opinion on merits.
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