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a claim for deduction under section 80-IA or 80-IB is allowed in the initial assessment year and is not subsequently withdrawn, the revenue is estopped from denying the deduction for subsequent years on the same grounds.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

Sudha, Gorakhpur vs. Income Tax Officer, Ward 2(2), Gorakhpur

In the result, the appeal of the assessee is held to be allowed for statistical purpose

ITA 130/VNS/2025[2016-2017]Status: DisposedITAT Varanasi31 Aug 2026AY 2016-2017

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2016-17 Sudha, Vs. Income Tax Officer Basantpur, Geeta Press, Ward-2(2), Income Tax Office, Gorakhpur-273001 Gorakhpur Pan: Avcps5016P (Appellant) (Respondent) Assessee By: None Revenue By: Shri. Sudipta Paul, Sr. Dr Date Of Hearing: 06.08.2026 Date Of Pronouncement: 31.08.2026 O R D E R Per Nikhil Choudhary, Am: This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit Nfac, Wherein The Ld. Cit(A) Vide His Order Dated 6.01.2024, Has Dismissed The Appeals Of The Assessee Against The Orders Of The Ld. Assessing Officer Passed Under Section 143(3) For The A.Y. 2016-17 On 17.12.2018. The Grounds Of Appeal Are As Under: - “1. Because The Appellate Order Dated 06.01.2024 Passed By Cit(A) In Appeal No. Cit(A), Gorakhpur/10296/2018-19, Impugned In The Present Appeal, Cannot Be Said To Have Been Passed In Accordance With Law Relating To Hearing & Disposal Of Appeal As Contained In Section 250 Of The Income Tax Act 1961. 2. Because Non-Compliance To The Notices Issued By The Id. Cit(A) For Hearing Of Appeal Was Solely For The Reason That The Appellant Was Prevented By "Sufficient & Reasonable Cause" (Being Un-Awareness Of The Notices Issued For Hearing As Income Tax Matters Was Being Handled By The Accountant Of The Appellant), Therefore The Cit(A) Had Erred In Law & On Facts In Dismissing The Appeal Ex-Parte Without Considering The "Reasonable Cause Of The Appellant.

For Appellant: NoneFor Respondent: Shri. Sudipta Paul, Sr. DR
Section 143(3)Section 250Section 50CSection 54

Kamalakannan Arumugam, Sakthivinayagapuram Melur, Tuticorin vs. Income Tax Officer, Ward-2, Tuticorin

In the result, grounds raised by the assessee in both the appeals are allowed for statistical purposes with above directions

ITA 3641/CHNY/2026[2017-2018]Status: DisposedITAT Chennai27 Aug 2026AY 2017-2018

Bench: Honourable George George K & Shri Gagan Goyalआयकर अपील सं./Ita No. 3640 & 3641/Chny/2026 ननिाारण वर्ा /Assessment Years: 2017-18, Kamalakannan Arumugam, V. Income Tax Officer, No.111/66/29D, Sksr Colony, Ward-2, Sakthivinayagapuram Melur, Tuticorin. Tuticorin, Tamil Nadu-628 002. [Pan: Anfpk7300R] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. T. Vasudevan & Ms. Karishma, Advocates, Ld. Ars. प्रत्यर्थी की ओर से /Revenue By : Mr. R. Raghupathy, Addl. Cit, Ld. Dr. सुनवाईकीतारीख/Date Of Hearing : 20.08.2026 घोषणाकीतारीख /Date Of Pronouncement : 27.08.2026 आदेश / O R D E R Per Gagan Goyal, Am: This Is An Appeal Preferred By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (A) / Nfac, (Hereinafter Referred To As The ‘Ld. Cit(A)’), Delhi Dated 14.05.2026 For The Assessment Year (Hereinafter Referred To As The ‘Ay’) 2017-18. Grouds Of Appeal

For Appellant: Mr. T. Vasudevan & MsFor Respondent: Mr. R. Raghupathy, Addl. CIT
Section 148Section 148ASection 270ASection 50C

Kamalakannan Arumugam, Sakthivinayagapuram Melur, Tuticorin vs. Income Tax Officer, Ward-2, Tuticorin, Income Tax Office

In the result, grounds raised by the assessee in both the appeals are allowed for statistical purposes with above directions

ITA 3640/CHNY/2026[2017-2018]Status: DisposedITAT Chennai27 Aug 2026AY 2017-2018

Bench: Honourable George George K & Shri Gagan Goyalआयकर अपील सं./Ita No. 3640 & 3641/Chny/2026 ननिाारण वर्ा /Assessment Years: 2017-18, Kamalakannan Arumugam, V. Income Tax Officer, No.111/66/29D, Sksr Colony, Ward-2, Sakthivinayagapuram Melur, Tuticorin. Tuticorin, Tamil Nadu-628 002. [Pan: Anfpk7300R] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. T. Vasudevan & Ms. Karishma, Advocates, Ld. Ars. प्रत्यर्थी की ओर से /Revenue By : Mr. R. Raghupathy, Addl. Cit, Ld. Dr. सुनवाईकीतारीख/Date Of Hearing : 20.08.2026 घोषणाकीतारीख /Date Of Pronouncement : 27.08.2026 आदेश / O R D E R Per Gagan Goyal, Am: This Is An Appeal Preferred By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (A) / Nfac, (Hereinafter Referred To As The ‘Ld. Cit(A)’), Delhi Dated 14.05.2026 For The Assessment Year (Hereinafter Referred To As The ‘Ay’) 2017-18. Grouds Of Appeal

For Appellant: Mr. T. Vasudevan & MsFor Respondent: Mr. R. Raghupathy, Addl. CIT
Section 148Section 148ASection 270ASection 50C

Sharadbhai Mansukhbhai Kumbhani, Amreli vs. The ITO Ward 3(3)(1), Surat

The appeal of the assessee is partly allowed

ITA 315/SRT/2026[2015-16]Status: DisposedITAT Surat24 Aug 2026AY 2015-16

Bench: Ms. Suchitra Kamble & Shri B.M. Biyanisharadbhai Mansukhbhai Kumbhani The Ito, Ward - 3(3)(1), 1, At. Dhudiya Agariya, Room No.219, Ta. Rajula Dist. Amreli, Vs. Aaykar Bhawan, Rajula. Majura Gate, Surat Pan: Asapk7378P (Appellant) : (Respondent) Assessee By : Shri Rasesh Shah, Ca Respondent By : Shri Ashish Kumar, Sr. Dr Date Of Hearing : 19.08.2026 Date Of Pronouncement : 24.08.2026 O R D E R Per : Suchitra Kamble, J M: The Appeal Filed By The Assessee Is Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [In Short “Cit(A)”] Dated 15.12.2025 For The Assessment Year (In Short “Ay”) 2015-16. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Learned Commissioner (Appeals), National Faceless Appeal Centre (Nfac), Delhi Erred In Confirming Action Of The Assessing Officer In Making Addition Of Rs1,04,23,220/-Bydisallowing Exemption Claimed U/S 54B Of The Act. 2. The Learned Commissioner (Appeals), National Faceless Appeal Centre (Nfac), Delhi Failed To Appreciate That Order U/S 263 Of The Act Has Been Restored To The Pcit By The Hon'Ble Tribunal, Rajkot & Hence The Order U/S 143(3) R.W.S. 263 Would Become Infructuous. Sharadbhai Mansukhbhai Kumbhani

For Appellant: Shri Rasesh Shah, CAFor Respondent: Shri Ashish Kumar, Sr. DR
Section 143(3)Section 263Section 50CSection 54B

Natvarlal Naranji Desai, Surat vs. ITO, Ward 2(2)(5), Surat

ITA 509/SRT/2026[2012-13]Status: DisposedITAT Surat10 Aug 2026AY 2012-13

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.509 /Srt/2026 [ "नधा"रणवष"/Assessment Year: 2012-13 ] Natvarlal Naranji Desai, Ito, Ward 2(2)(5), Vs. At Valthan, Po Mankna Kamrej, Ayakar Bhawan, Maura Gate, Mankna B.O, Valthan, Surat, Gujarat-395001 Surat, Gujarat-394325 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Azlpd5995K (अपीलाथ"/Appellant) (""यथ"/Respondent) Appellant By : Shri Rasesh Shah, Ar Respondent By : Shri Ajay Uke, Ld. Sr. Dr Date Of Hearing : 18/05/2026 10/08/2026 Date Of Pronouncement : : Order : Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2012-13, Is Directed Against The Order Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 16.01.2026 By The National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income Tax (Appeals) [In Short ‘Ld.Cit(A)’] Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer (In Short ‘Ao’) U/S 147 R.W.S. 143(3) Of The Act, Dated 27.12.2019. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows: 1. In The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Assessing Officer Has Erred In Re-Opening Assessment U/S 147 By Issuing The Notice U/S 148 Of The I.T. Act, 1961. 2. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Cit(A) Has Erred In Confirming The Action Of Assessing Officer Making

For Appellant: Shri Rasesh Shah, ARFor Respondent: Shri Ajay Uke, Ld. Sr. DR
Section 143(3)Section 147Section 148Section 250Section 50C