Prabhudas Veljibhai Chaudhari v. PCIT (2021) 431 ITR 246 (Guj)(HC)

S. 264 :Commissioner – Revision of other orders – Rejection of application on ground of bar of limitation – Failure to decide revised capital gains- Matter remanded to decide the issue on section 50C [ S. 50C, 54 , Art , 226 ]

The Principal Commissioner rejected application was barred by limitation  however, he decided the merits of the application as well but did not record any finding as regards the assessee’s contention with respect to section 50C.  On writ  the matter was remitted to the Principal Commissioner for adjudicating the issue with regard to section 50C without reopening the issue with regard to limitation. Matter remanded.