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Issues Involved:
1. Interpretation of provisions of Income-tax Act, 1961 regarding capital gains exemption and valuation of property. 2. Validity of remanding a case by the Tribunal for fresh consideration. 3. Application of legal principles in exercising discretion for remand. 4. Determination of tax liability on sale of property components. 5. Tax exemption claim based on historical notifications. Judgment Details: The High Court of Madhya Pradesh addressed a reference u/s 256(1) of the Income-tax Act, 1961, where the Tribunal raised questions regarding the valuation of property and tax liability on capital gains. The case involved an individual assessed for capital gains arising from the sale of land plots. The Income-tax Officer rejected the claimed exemption and estimated market values u/s 52(2) of the Act. The Appellate Assistant Commissioner partially allowed the appeal, directing a re-calculation of capital gains. The Tribunal remanded the case for further consideration, leading to the reference to the High Court. Upon review, the High Court reframed the questions to focus on the validity of the Tribunal's remand decision. Legal principles were cited emphasizing that the Tribunal's discretion for remand should align with reason and justice, especially when all essential facts are on record. The Court found that the Tribunal's remand was unjustified as the Appellate Assistant Commissioner had thoroughly considered all relevant evidence, including sale deeds and comparative sales data. Therefore, the Tribunal's decision to remand the case was deemed inappropriate. Regarding the issue of bifurcating the value of land and structures in a property sale, the Court noted that the Tribunal did not provide a clear finding, leading to the conclusion that no legal question arose from their order on this matter. As for the tax exemption claim based on historical notifications, the Court referenced a previous decision, ruling in favor of the Revenue and against the assessee. In conclusion, the High Court answered the reference questions accordingly, emphasizing that parties would bear their own costs in this matter.
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