Deeming Fiction of Sec 50C can’t be brought into Section 54/54F Exemption

Dhanveer Singh Gambhir Vs ITO (ITAT Indore) The issue under consideration is whether the Section 50C need to be complied at the time of computation of exemption u/s 54 or 54F? ITAT states that, Section 54 and Section 54F are exemption provisions and a complete code in itself and since it is a complete code in itself, computation of eligible exemption has to be worked out within its framework as far as possible and deeming fiction contained in any other provision cannot be brought into section 54F. The deeming fiction created by virtue of section 50C in determining ‘capital gain’ fr...