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opinion that for the purpose of exemption under section 54EC of the Act, deeming fiction contained in section 50C of the Act cannot be ignored ... would have no applicability while computing the exemption as provided in section 54EC of the Act. He contended that section 45 which is a charging

opinion that for the purpose of exemption under section 54EC of the Act, deeming fiction contained in section 50C of the Act cannot be ignored ... would have no applicability while computing the exemption as provided in section 54EC of the Act. He contended that section 45 which is a charging