Section 50C of the Income Tax Act

Income-tax Act, 2025: s.78

Section 50C of the Income-tax Act, 1961 corresponds to section 78 (Special provision for full value of consideration in certain cases) of the Income-tax Act, 2025.

Read section 78 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 50C is CIT v. Alom Extrusions Ltd. (319 ITR 306), cited in 1,344 of the 3,223 judgments on BharatTax that turn on this section.

Leading authorities on Section 50C

CIT v. Alom Extrusions Ltd.
319 ITR 306 · 2009 · Supreme Court
1,344
citing judgments

A proviso inserted into a section to remedy unintended consequences, make the section workable, or supply an obvious omission must be read retrospectively in operation to give effect to the section as a whole.

CIT v. Chettinad Logistics (P) Ltd.
80 Taxmann.com 221 · 2017 · High Court
444
citing judgments

Section 14A cannot be invoked to disallow expenditure if the assessee has not earned any exempt income in the relevant assessment year. The Explanation to Section 14A is prospective in nature.

Allied Motors (P) Ltd. v. CIT
224 ITR 677 · 1997 · Supreme Court
398
citing judgments

Amendments to the Income-tax Act that are curative, clarificatory, or beneficial in nature apply retrospectively from the date the original statutory provision was introduced, even if not explicitly stated.

CIT v. Vatika Township (P.) Ltd.
49 Taxmann.com 249 · 2014 · Supreme Court
294
citing judgments

Legislation is ordinarily presumed not to have retrospective operation, especially for taxing statutes unless explicitly stated or when intended to remove hardship for the assessee. The decision clarifies the principles for determining whether an amendment to a taxing statute applies prospectively or retrospectively, distinguishing between clarificatory and substantive amendments.

CIT v. Paul Brothers
216 ITR 548 · 1995 · High Court
164
citing judgments

Once a claim for deduction under section 80-IA or 80-IB is allowed in the initial assessment year and is not subsequently withdrawn, the revenue is estopped from denying the deduction for subsequent years on the same grounds.

Sunil Kumar Agarwal v. CIT
372 ITR 83 · 2015 · High Court
159
citing judgments

The Assessing Officer is duty-bound to refer the valuation of property to the Departmental Valuation Officer under Section 50C(2) when an assessee disputes the stamp duty valuation or if there is a discrepancy between the actual sale consideration and the guideline value. This reference is mandatory, even if not explicitly requested by the assessee, to ensure a realistic fair market value and avoid injustice.

Kapurchand Shrimal v. CIT
131 ITR 451 · 1981 · Supreme Court
143
citing judgments

Appellate authorities in income-tax proceedings have the jurisdiction and duty to correct all errors of lower authorities. They must remit matters for proper or fresh adjudication and issue appropriate directions to ensure substantial justice, unless expressly forbidden by statute.

Nirma Industries Ltd. v. DCIT
283 ITR 402 · 2006 · High Court
136
citing judgments

Interest received on delayed payments for sales is considered part of the sale proceeds and is eligible for deduction under Section 80-IA as business income.

Rajeev Kumar Agarwal v. ACIT
149 ITD 363 · 2014 · ITAT
104
citing judgments

Curative amendments, such as a proviso to Section 40(a)(ia) introduced to remove undue hardship, apply retrospectively even without specific legislative declaration, rectifying shortcomings and obviating unintended difficulties.

Ltd. v. DCIT
76 Taxmann.com 268 · 2016 · High Court
101
citing judgments

Where the Assessing Officer performs an elaborate analysis to determine disallowance under Section 14A, the mere absence of a specific record of dissatisfaction with the assessee's calculation does not nullify the disallowance, provided the statutory steps are followed.

Judgments on Section 50C

Vikas Jain, Kanpur vs. ACIT-CC 2(1)(1), Kanpur

In the result, the appeal of the assessee is partly allowed

ITA 434/LKW/2024[2015-16]Status: DisposedITAT Lucknow31 Dec 2025AY 2015-16

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2015-16 Vikas Jain, Vs. The Acit, H-2/1, Kidwai Nagar, Kanpur- Circle 2(1)(1), Kanpur 208001 208006 Pan: Abqpj8049R (Appellant) (Respondent) Assessee By: Sh. Rakesh Garg, Adv Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 07.10.2025 Date Of Pronouncement: 31.12.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac On 17.05.2024 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Order Passed By The Ld. Assessing Officer Under Section 147 R.W.S. 143(3) For The A.Y. 2015-16 On 27.12.2018. The Grounds Of Appeal Are As Under:- “01. Because There Being No Reason To Believe, Far From There Being Any Material To Form Reasons To Believe, The Proceedings Initiated Right From Issue Of Notice U/S. 148 & The Re-Assessment Framed Thereof Are All Without Jurisdiction Bad In Law, The Order Passed Be Quashed. 02. Because The So-Called Reasons Having Been Recorded Applying Explanation 2(A) To Section 147, Of The Act Which Not Being Applicable, The Very Reason To Believe Being Contrary To The Mandate Of The Section, The Proceedings- Initiated U/S 148, The Reassessment Framed Are All Contrary To The Provisions Of Law, Be Quashed. 03. Because The Approval Given By The Competent Authority U/S 151, Being Mechanical In Nature Without Verification Of Facts, The Notice Issued U/S 148 & The Reassessment Framed Thereafter Be Quashed.

For Appellant: Sh. Rakesh Garg, AdvFor Respondent: Sh. Amit Kumar, DR
Section 143(1)Section 147Section 148Section 151Section 156Section 48Section 50C

Shri Shah Afroze Hossain, Bhagalpur vs. Dy. CIT, Cent, Cir-2, Patna

In the result, the appeal of the assessee is partly allowed in terms indicated above

ITA 711/PAT/2024[2022-23]Status: DisposedITAT Patna30 Dec 2025AY 2022-23

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.711/Pat/2024 Assessment Year: 2022-23 Shri Shah Afroze Hossain.….…………………....…………………....Appellant 12, Shahganjhi, Habibpur, Bhagalpur, Bihar-812006. [Pan: Aapph1112D] Vs. Dcit, Central Circle-2, Patna..………....…..………………….…..... Respondent Appearances By: Shri Manish Rastogi, Adv., Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : December 30, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A), Patna-3 (Hereinafter Referred To As “Ld. Cit(A)”) Dated 22.10.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Assessment Year 2022–23 Declaring A Total Income Of ₹75,56,770, Comprising The Income From Business Of ₹6,54,569, Long- Term Capital Gains: ₹49,60,293 & Income From Other Sources Of ₹19,35,912. A Search & Seizure Operation Under Section 132 Of The Act Was Carried Out On 29.12.2022 At The Residential & Business Premises Of The Assessee Pursuant To A Warrant Of Authorisation Issued By The Director Of Investigation, Patna. During The Course Of The Search

Section 132Section 142(1)Section 143(2)Section 250Section 50CSection 50C(2)

Jyoti Embroidery Private Limited, Mumbai vs. Income Tax Officer Ward 10(2)(1), Mumbai

In the result, assessee’s appeal is allowed

ITA 5637/MUM/2025[2013-14]Status: DisposedITAT Mumbai24 Dec 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2013-14 Jyoti Embroidery Private Income Tax Officer, Limited, Ward 10 (2)(1), V1-0 Vara’S House, 1St Aaykar Bhavan, M.K. Road, Vs. Ganeshwadi, Ground Floor, Mumbai – 400020. Near Mj Market, Zaveri Bazar, Mumbai – 400002 Pan – Aaacj 0872 G (Appellant) (Respondent) Present For: Assessee By : Shri Dharan Gandhi, Ld. Ar Revenue By : Ms. Kavitha Kaushik, Ld. Sr. Dr Date Of Hearing : 04.11.2025 Date Of Pronouncement : 24.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 28.07.2025 Impugned Herein Passed By The National Faceless Appeal Center (Ld. Commissioner Of Income Tax (Appeals) (For Short Ld. Commissioner) Under Section 250 Of The Income Tax Act, 1961 (For Short The ‘Act’) For The Ay 2013-14. 2. In The Instant Case, The Assessee Has Sold A Land To M/S. Yogeshwar Farms Private Limited For A Sale Consideration Of Rs. 2,15,00,000/- & Claimed The Long Term Capital Gain Of Rs. 1,58,00,000/- In The Return Of Income Filed On Dated 28Th September, 2013, Declaring Total Income Of Rs. 1,57,50,330/-. The Ao Considered The Said Claim Of The Assessee & Ultimately Found That The Stamp Duty Value Of The Property Is Of 2 Jyoti Embroidery Private Limited Rs.387,39,000/- & The Assessee Has Sold The Property For Rs.2,15,00,000/- I.E. Less Than The Value Adopted Or Assessed By The Valuation Authorities Of The State Government & Therefore He Vide Assessment Order Dated 25.09.2017 Under Section 143 (3) Read With Under Section 147 Of The Act, Ultimately Made The Addition Of Rs. 1,72,39,000/- Being Differential Amount Between The Stamp Duty Valuation & The Value Declared By The Assessee.

For Appellant: Shri Dharan Gandhi, Ld. ARFor Respondent: Ms. Kavitha Kaushik, Ld. SR. DR
Section 143Section 147Section 250Section 55