Section 49 IS the cost-determination mechanism for carve-out acquisitions.
13. Refund / credit
Standard.
14. Return / disclosure reporting
ITR Schedule CG at future sale.
15. Penalty exposure
Section 270A on incorrect cost claim.
16. Prosecution exposure
Section 277.
17. Cross-statute interplay
Hindu Succession Act; Indian Succession Act; Companies Act.
18. Repeal & saving — 1961 → 2025
Preserved.
HISTORICAL CONTEXT
Section 49 establishes the stepped cost basis for assets acquired through section 47 carve-out transfers. The principle: where an asset is acquired tax-neutrally (gift / inheritance / partition / amalgamation / etc.), the transferee takes the PREVIOUS OWNER'S cost basis for future computation. This ensures the temporal preservation of the gain — postponed but not eliminated.
Holding period also carries over from previous owner. So if A inherited property from his father (who held it 20 years), A's holding period for LTCG / STCG purposes is the FATHER'S holding period (20 years), not from the date of inheritance. This is a generous structural feature that preserves long-term characterisation across generations.
Indexation (pre-FA 2024 abolition) operates from the previous owner's acquisition year, not the inheritance / gift year. This is judicially established (Manjula Shah; Bom HC) and remains the operative interpretation. For pre-1-4-2001 acquisitions, section 55(2)(b) FMV election may be exercised by the transferee.
Practitioner significance — section 49 + section 47 + section 55 together preserve cost / holding period across multiple generational transfers. Documentation discipline — chain of title from original acquisition + previous owner's cost evidence + improvement expenditure across generations.
The transition to the Income-tax Act, 2025 preserves section 49 architecture.
FINANCE ACT AMENDMENT TIMELINE
■ FA 1962 — Section 49 came into force.
■ FA 1987 — HUF / firm dissolution framework refined.
■ FA 1992 — Section 49(2) amalgamation shareholder cost basis.
■ FA 2017 — Indexation base year shifted to 1-4-2001; s. 55(2)(b) election extended.
■ FA 2024 — Indexation abolition for post-23-7-2024 transfers; s. 49 cost-basis architecture preserved.
▸ Commissioner of Income-tax v. B.C. Srinivasa Setty (1981) 128 ITR 294 ; (1981) 2 SCC 460 (Supreme Court)
Facts. The assessee transferred goodwill of a self-generated nature. The Department sought to tax the consideration as capital gains; the assessee contended that no cost of acquisition could be ascertained, hence the computation provisions failed.
Issue. Whether capital gains arises where the asset has no ascertainable cost of acquisition — i.e., whether the charging provision can be invoked independently of a workable computation provision.
HELD. The charging section and the computation provisions form an integrated code; if the computation provisions cannot apply (because the cost is incapable of ascertainment), the charge itself fails. Self-generated goodwill is not taxable as capital gains.
“The charging section and the computation provisions together constitute an integrated code. When there is a case to which the computation provisions cannot apply at all, it is evident that such a case was not intended to fall within the charging section.”
Relevance. Anchor for the 'charge fails when computation fails' doctrine — useful in valuation impasses, self-generated assets, and computational ambiguity (though now largely overtaken by section 55(2)(a)(i) deeming cost as nil).
Facts. The Department sought to apply a surcharge provision retrospectively to block-period assessments. The assessee contended that the amendment was substantive and could not have retrospective operation absent express legislative direction.
Issue. Whether amendments to taxing statutes operate prospectively unless the legislature has expressly or by necessary implication conferred retrospective effect.
HELD. The Constitution Bench reaffirmed the general rule against retrospectivity of taxing statutes. A taxing provision must be construed prospectively unless the language compels otherwise; mere insertion or substitution by amendment is not sufficient to deny vested rights.
“Of the various rules guiding how a legislation has to be interpreted, one established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to have a retrospective operation.”
Relevance. Anchor authority for any argument that an amendment to a charging or computational provision must apply only from the AY notified — useful in transitional disputes around FA 2025 and the 1961 → 2025 changeover.
Facts. Section 52(2) (since deleted) deemed sale consideration to be FMV where FMV exceeded the declared consideration by 15%. The Department applied it on a literal reading even when the assessee had not in fact received more than the declared price.
Issue. Whether a deeming provision in a charging schema can be construed literally where its plain reading produces a result manifestly contrary to legislative object.
HELD. The Court read down section 52(2) to apply only where the assessee had actually received consideration in excess of the declared sum. A literal construction yielding absurd or unjust results must yield to an object-based interpretation; the CBDT's contemporaneous Circular No. 96 was held binding on the Revenue.
“It is well settled that a literal construction of a statutory provision ought not to be adopted if it produces a manifestly unjust result… Where a literal construction creates an anomaly, the courts will adopt that construction which avoids the anomaly.”
Relevance. Anchor authority for purposive construction of deeming fictions across the 1961 Act — applies wherever a deeming clause (e.g., s. 50C, s. 56(2)(x), s. 2(22)(e)) yields a result contrary to legislative purpose.
▸ Mathuram Agrawal v. State of Madhya Pradesh (1999) 8 SCC 667 ; (2000) 1 SCR 1 (Supreme Court)
Facts. A municipal levy was challenged on the ground that the charging provision did not clearly specify the rate, the persons charged, and the measure of tax.
Issue. Whether a tax can be imposed in the absence of a clear, unambiguous charging provision identifying the subject, measure, rate, and incidence.
HELD. Article 265 demands that tax be levied only by clear authority of law. The four components — taxable event, person, rate, and measure — must be clearly discernible from the charging provision; ambiguity is fatal to the levy.
“The intention of the Legislature in a taxation statute is to be gathered from the language of the provisions, particularly when the language is plain and unambiguous. In a taxing Act it is not possible to assume any intention or governing purpose other than what is given expression to.”
Relevance. Foundational authority on the rigour required of charging sections — underpins arguments that ambiguous deeming fictions, surcharge formulas, and rate prescriptions must be strictly construed.
▸ Commissioner of Income-tax v. Excel Industries Ltd. (2013) 358 ITR 295 ; (2014) 2 SCC 1 (Supreme Court)
Facts. The assessee, an export-oriented unit, received DEPB licences and Advance Licences. The Department sought to tax the value of these incentives on accrual at the time of issue; the assessee contended that no income accrued until the licence was actually used or sold.
Issue. When does income accrue under the mercantile system — at the moment a right is created, or at the moment the right becomes enforceable as a debt?
HELD. Income accrues only when there is a corresponding liability of the other party. Mere creation of a contingent or unmatured right does not amount to accrual; the right must crystallise into a debt before tax incidence.
“Income accrues when there arises in favour of the assessee a debt — when there is a corresponding liability of the other party to pay the amount. It is not enough that the right has come into being; the right must ripen into a debt.”
Relevance. Anchor for accrual-vs-receipt timing disputes under section 5 / section 145 — relevant for retention monies, export incentives, contingent claim settlements, milestone-based contracts.
CBDT CIRCULARS — ECOSYSTEM
▸ CBDT Circular No. 14(XL-35) of 1955 dated 11 April 1955
Subject. Duty of officers to assist assessees in claiming and securing relief
Substance. Foundational circular directing that the AO should not exploit assessee ignorance to deny legitimate reliefs; officer is required to draw attention to refunds or reliefs to which the assessee is entitled. The circular has been judicially noted in several appellate decisions and remains operative for first-appellate practice.
Substance. Explained the FA 1987 / FA 1989 amendments unifying the previous year with the financial year preceding the AY, including transitional provisions for assessees with different accounting years. Useful in any controversy on the timing of accrual / chargeability for early post-1989 AYs.
▸ CBDT Circular No. 5 of 2014 dated 11 February 2014
Subject. Section 14A — dis-allowance even where no exempt income earned (since modulated)
Substance. Initially directed AOs to apply Rule 8D disallowance under section 14A even where no exempt income was earned in the year; subsequently modulated by Cheminvest (Del HC) and Maxopp (SC). FA 2022 amendment to section 14A re-asserted the position but remains under litigation.
STATUTORY ARCHITECTURE — 18-ROW MAP
01. Section & marginal note
Section 49 — 'Cost of acquisition with reference to certain modes' — Chapter IV-D.
02. Sub-section structure
Multiple sub-sections covering different transfer categories.
03. Operative trigger
Asset acquired through gift / inheritance / partition / amalgamation / etc.
04. Persons affected
Transferees in s. 47-style transfers.
05. Time anchor — PY / AY
Cost basis fixed at previous owner's acquisition.
06. Income anchor
Operative for future s. 45 / s. 48 computation.
07. Residential-status nexus
Standard.
08. Rate / charge mechanism
Per s. 111A / 112 / 112A on subsequent sale.
09. TDS / TCS interaction
Standard at future sale.
10. Advance-tax obligation
On future sale.
11. Presumptive provisions
N/A.
12. Exemption / deduction mechanism
Section 49 IS the cost-determination mechanism for carve-out acquisitions.
13. Refund / credit
Standard.
14. Return / disclosure reporting
ITR Schedule CG at future sale.
15. Penalty exposure
Section 270A on incorrect cost claim.
16. Prosecution exposure
Section 277.
17. Cross-statute interplay
Hindu Succession Act; Indian Succession Act; Companies Act.
18. Repeal & saving — 1961 → 2025
Preserved.
HISTORICAL CONTEXT
Section 49 establishes the stepped cost basis for assets acquired through section 47 carve-out transfers. The principle: where an asset is acquired tax-neutrally (gift / inheritance / partition / amalgamation / etc.), the transferee takes the PREVIOUS OWNER'S cost basis for future computation. This ensures the temporal preservation of the gain — postponed but not eliminated.
Holding period also carries over from previous owner. So if A inherited property from his father (who held it 20 years), A's holding period for LTCG / STCG purposes is the FATHER'S holding period (20 years), not from the date of inheritance. This is a generous structural feature that preserves long-term characterisation across generations.
Indexation (pre-FA 2024 abolition) operates from the previous owner's acquisition year, not the inheritance / gift year. This is judicially established (Manjula Shah; Bom HC) and remains the operative interpretation. For pre-1-4-2001 acquisitions, section 55(2)(b) FMV election may be exercised by the transferee.
Practitioner significance — section 49 + section 47 + section 55 together preserve cost / holding period across multiple generational transfers. Documentation discipline — chain of title from original acquisition + previous owner's cost evidence + improvement expenditure across generations.
The transition to the Income-tax Act, 2025 preserves section 49 architecture.
FINANCE ACT AMENDMENT TIMELINE
■ FA 1962 — Section 49 came into force.
■ FA 1987 — HUF / firm dissolution framework refined.
■ FA 1992 — Section 49(2) amalgamation shareholder cost basis.
■ FA 2017 — Indexation base year shifted to 1-4-2001; s. 55(2)(b) election extended.
■ FA 2024 — Indexation abolition for post-23-7-2024 transfers; s. 49 cost-basis architecture preserved.
■ FA 2025 — Cosmetic.
■ Income-tax Act, 2025 — Section 49 successor, operative 1-4-2026.
JUDICIAL EVOLUTION — VERIFIED LANDMARK AUTHORITIES
▸ Commissioner of Income-tax v. B.C. Srinivasa Setty (1981) 128 ITR 294 ; (1981) 2 SCC 460 (Supreme Court)
Facts. The assessee transferred goodwill of a self-generated nature. The Department sought to tax the consideration as capital gains; the assessee contended that no cost of acquisition could be ascertained, hence the computation provisions failed.
Issue. Whether capital gains arises where the asset has no ascertainable cost of acquisition — i.e., whether the charging provision can be invoked independently of a workable computation provision.
HELD. The charging section and the computation provisions form an integrated code; if the computation provisions cannot apply (because the cost is incapable of ascertainment), the charge itself fails. Self-generated goodwill is not taxable as capital gains.
“The charging section and the computation provisions together constitute an integrated code. When there is a case to which the computation provisions cannot apply at all, it is evident that such a case was not intended to fall within the charging section.”
Relevance. Anchor for the 'charge fails when computation fails' doctrine — useful in valuation impasses, self-generated assets, and computational ambiguity (though now largely overtaken by section 55(2)(a)(i) deeming cost as nil).
▸ Commissioner of Income-tax v. Vatika Township Pvt. Ltd. (2014) 367 ITR 466 ; (2015) 1 SCC 1 (Supreme Court — 5-Judge Constitution Bench)
Facts. The Department sought to apply a surcharge provision retrospectively to block-period assessments. The assessee contended that the amendment was substantive and could not have retrospective operation absent express legislative direction.
Issue. Whether amendments to taxing statutes operate prospectively unless the legislature has expressly or by necessary implication conferred retrospective effect.
HELD. The Constitution Bench reaffirmed the general rule against retrospectivity of taxing statutes. A taxing provision must be construed prospectively unless the language compels otherwise; mere insertion or substitution by amendment is not sufficient to deny vested rights.
“Of the various rules guiding how a legislation has to be interpreted, one established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to have a retrospective operation.”
Relevance. Anchor authority for any argument that an amendment to a charging or computational provision must apply only from the AY notified — useful in transitional disputes around FA 2025 and the 1961 → 2025 changeover.
▸ K.P. Varghese v. Income-tax Officer, Ernakulam (1981) 131 ITR 597 ; (1981) 4 SCC 173 (Supreme Court — 3-Judge Bench)
Facts. Section 52(2) (since deleted) deemed sale consideration to be FMV where FMV exceeded the declared consideration by 15%. The Department applied it on a literal reading even when the assessee had not in fact received more than the declared price.
Issue. Whether a deeming provision in a charging schema can be construed literally where its plain reading produces a result manifestly contrary to legislative object.
HELD. The Court read down section 52(2) to apply only where the assessee had actually received consideration in excess of the declared sum. A literal construction yielding absurd or unjust results must yield to an object-based interpretation; the CBDT's contemporaneous Circular No. 96 was held binding on the Revenue.
“It is well settled that a literal construction of a statutory provision ought not to be adopted if it produces a manifestly unjust result… Where a literal construction creates an anomaly, the courts will adopt that construction which avoids the anomaly.”
Relevance. Anchor authority for purposive construction of deeming fictions across the 1961 Act — applies wherever a deeming clause (e.g., s. 50C, s. 56(2)(x), s. 2(22)(e)) yields a result contrary to legislative purpose.
▸ Mathuram Agrawal v. State of Madhya Pradesh (1999) 8 SCC 667 ; (2000) 1 SCR 1 (Supreme Court)
Facts. A municipal levy was challenged on the ground that the charging provision did not clearly specify the rate, the persons charged, and the measure of tax.
Issue. Whether a tax can be imposed in the absence of a clear, unambiguous charging provision identifying the subject, measure, rate, and incidence.
HELD. Article 265 demands that tax be levied only by clear authority of law. The four components — taxable event, person, rate, and measure — must be clearly discernible from the charging provision; ambiguity is fatal to the levy.
“The intention of the Legislature in a taxation statute is to be gathered from the language of the provisions, particularly when the language is plain and unambiguous. In a taxing Act it is not possible to assume any intention or governing purpose other than what is given expression to.”
Relevance. Foundational authority on the rigour required of charging sections — underpins arguments that ambiguous deeming fictions, surcharge formulas, and rate prescriptions must be strictly construed.
▸ Commissioner of Income-tax v. Excel Industries Ltd. (2013) 358 ITR 295 ; (2014) 2 SCC 1 (Supreme Court)
Facts. The assessee, an export-oriented unit, received DEPB licences and Advance Licences. The Department sought to tax the value of these incentives on accrual at the time of issue; the assessee contended that no income accrued until the licence was actually used or sold.
Issue. When does income accrue under the mercantile system — at the moment a right is created, or at the moment the right becomes enforceable as a debt?
HELD. Income accrues only when there is a corresponding liability of the other party. Mere creation of a contingent or unmatured right does not amount to accrual; the right must crystallise into a debt before tax incidence.
“Income accrues when there arises in favour of the assessee a debt — when there is a corresponding liability of the other party to pay the amount. It is not enough that the right has come into being; the right must ripen into a debt.”
Relevance. Anchor for accrual-vs-receipt timing disputes under section 5 / section 145 — relevant for retention monies, export incentives, contingent claim settlements, milestone-based contracts.
CBDT CIRCULARS — ECOSYSTEM
▸ CBDT Circular No. 14(XL-35) of 1955 dated 11 April 1955
Subject. Duty of officers to assist assessees in claiming and securing relief
Substance. Foundational circular directing that the AO should not exploit assessee ignorance to deny legitimate reliefs; officer is required to draw attention to refunds or reliefs to which the assessee is entitled. The circular has been judicially noted in several appellate decisions and remains operative for first-appellate practice.
▸ CBDT Circular No. 549 dated 31 October 1989
Subject. Explanatory notes — Finance Act 1989 amendments (incl. PY unification)
Substance. Explained the FA 1987 / FA 1989 amendments unifying the previous year with the financial year preceding the AY, including transitional provisions for assessees with different accounting years. Useful in any controversy on the timing of accrual / chargeability for early post-1989 AYs.
▸ CBDT Circular No. 5 of 2014 dated 11 February 2014
Subject. Section 14A — dis-allowance even where no exempt income earned (since modulated)
Substance. Initially directed AOs to apply Rule 8D disallowance under section 14A even where no exempt income was earned in the year; subsequently modulated by Cheminvest (Del HC) and Maxopp (SC). FA 2022 amendment to section 14A re-asserted the position but remains under litigation.
WORKED EXAMPLES
Illustration — Illustration 1 — Inherited property
Facts. A inherits property from father in 2020; father purchased 1995 for Rs 5 L. A sells in PY 2024-25 for Rs 1.5 cr.
Computation.
S. 49(1)(iii)(a) — Inheritance cost basis = father's cost Rs 5 L.
Holding period — from 1995 (father's acquisition) → LTCG (> 24 months).
S. 55(2)(b) — Election: cost OR FMV as on 1-4-2001 (since pre-1-4-2001 purchase).
If FMV 1-4-2001 = Rs 12 L → use Rs 12 L as cost.
Post FA 2024 (transfer post-23-7-2024) — 12.5% rate, no indexation OR 20% with indexation (choice).
Result. Section 49 cost basis carry-over preserves stepped cost; section 55(2)(b) election for old assets.
Illustration — Illustration 2 — Gifted shares
Facts. B gifts shares to son C; B's cost Rs 50,000; FMV at gift Rs 5 L. C sells in PY 2024-25 for Rs 8 L.
Computation.
S. 49(1)(ii) — Gift cost basis = B's cost Rs 50,000.
S. 56(2)(x) — Relative-gift carve-out → no income for C on receipt.
C's holding period — from B's original acquisition.
Sale Rs 8 L − Rs 50,000 = Rs 7.5 L LTCG.
Tax per s. 112A (listed) or s. 112 framework.
Result. Gift carve-out + stepped cost basis preserves full future taxation.
Illustration — Illustration 3 — Amalgamation shareholder swap
Facts. D held 100 shares of P Ltd (cost Rs 50 each); P amalgamates with Q Ltd; D receives 80 shares of Q Ltd.
Computation.
S. 49(2) — Q-shares cost basis = D's P-shares cost.
Total cost Rs 5,000 (Rs 50 × 100).
80 Q shares' cost = Rs 5,000 / 80 = Rs 62.50 per share.
On future sale of Q shares — LTCG using stepped basis.
Holding period — from D's original P-share acquisition.
Result. Amalgamation shareholder cost basis carry-over preserves continuity.
Illustration — Illustration 4 — HUF partition
Facts. HUF partitions in 2023; A receives ancestral house. HUF held the house from 1970.
Computation.
S. 47(i) — HUF partition carve-out.
S. 49(1)(i) — A's cost basis = HUF's original cost (1970).
Pre-1-4-2001 → s. 55(2)(b) FMV election available.
Holding period from 1970 → LTCG.
Future sale by A computed at stepped basis.
Result. HUF partition tax-neutral; cost preserved across decades.
Illustration — Illustration 5 — Will / inheritance + improvement
Facts. Mother bequeaths property to E. Mother purchased 2005 (Rs 20 L); spent Rs 10 L improvement 2015. E sells 2024 for Rs 1 cr.
Computation.
S. 49(1)(ii) — Will cost basis = mother's cost.
Section 55(1)(b) — Cost of improvement also stepped.
Effective cost — Rs 20 L (original) + Rs 10 L (improvement).
Pre-FA 2024 — indexation from 2005 acquisition + 2015 improvement.
Post-FA 2024 — 12.5% no indexation OR 20% indexed (choice).
Result. Cost includes both original + improvement; preserves full economic basis.
PRACTITIONER PLANNING NOTES
■ Indexation post FA 2024 — abolished for unlisted assets; listed equity 12.5% without indexation (post 23-7-2024).
■ FA 2024 LTCG rate harmonised at 12.5% across asset classes (most); listed equity threshold Rs 1.25 L.
■ Holding period — listed securities 12 months; unlisted shares 24 months; immovable property 24 months (FA 2024 reduction).
■ Section 50C / 50CA stamp value parallel — preserve actual-sale-consideration documentation.
■ Section 56(2)(x) parallel for buyer (gift framework).
■ Section 54 / 54F / 54EC reinvestment exemptions — strict timing + investment-pattern compliance.
■ Capital Gains Account Scheme (CGAS) — for un-utilised exemption funds before due date.
■ Section 47 carve-outs — corporate restructuring / family settlements / inheritance.
■ Section 49 stepped-up cost basis — for inherited / gifted / transferred assets.
■ Section 50 depreciable asset block — STCG framework regardless of holding period.
■ Section 50B slump sale — net worth methodology + Rule 11UAE for unlisted shares.
■ Section 55(2)(b) FMV election — for assets held before 1-4-2001; second-best election.
■ Form 26QB — TDS on immovable property > Rs 50 L (s. 194-IA).
■ Documentation discipline — purchase / sale deeds + valuation + reinvestment evidence — 7 years.
■ Annual practitioner review of FA changes to indexation / rates / thresholds.
LITIGATION DEFENCE
■ Strict construction — Mathuram Agrawal.
■ Object-based — K.P. Varghese.
■ Prospective amendment — Vatika Township for FA 2024 indexation abolition.
■ BC Srinivasa Setty — computation impossibility (self-generated assets).
■ Excel Industries accrual — for sale-completion timing.
■ Vodafone International — for cross-border transfer characterisation.
■ Calcutta Discount Article 226 — for jurisdictional challenges.
■ Section 47 carve-out defence — preserve corporate restructuring documentation.
■ Section 50C stamp value challenge — produce market evidence / valuation officer reference.
■ Section 54 / 54F reinvestment defence — preserve CGAS deposit + reinvestment evidence.
■ Section 49 stepped-up cost defence — preserve inheritance / gift documentation.
■ Slump sale defence — preserve net worth computation + lump-sum nature evidence.
■ Beneficial circulars defence.
■ Section 273B reasonable-cause defence.
■ Section 270A bona-fide claim defence (Reliance Petroproducts anchor).
■ Holding-period documentation — share certificates / property registry.
PROCEDURE
Step 1. Verify mode of acquisition
Falls within s. 47 / s. 49.
Step 2. Identify previous owner
Donor / testator / HUF / amalgamating company.
Step 3. Document previous owner's cost
Original purchase deed.
Step 4. Document improvement expenditure
Across generations.
Step 5. Apply s. 49 cost basis
Stepped from previous owner.
Step 6. Apply s. 55(2)(b) election
For pre-1-4-2001 assets.
Step 7. Determine holding period from previous owner
Not from transfer date.
Step 8. STCG vs LTCG classification
Per total holding.
Step 9. Apply s. 48 computation
With s. 49 cost.
Step 10. Apply indexation (pre-23-7-2024 LTCG)
From previous owner's acquisition year.
Step 11. Apply FA 2024 framework (post-23-7-2024)
12.5% no indexation OR choice option.
Step 12. Apply reinvestment exemptions
S. 54 / 54F / 54EC.
Step 13. ITR Schedule CG
Disclose stepped basis.
Step 14. Documentation 7 years
Chain of title + cost evidence.
Step 15. Annual FA update
Track changes.
PRACTITIONER CHECKLIST
☐ Mode of acquisition verified.
☐ Previous owner identified.
☐ Previous owner's cost documented.
☐ Improvement expenditure across owners.
☐ Section 49 stepped cost applied.
☐ Section 55(2)(b) FMV election considered.
☐ Holding period from previous owner.
☐ STCG / LTCG classification.
☐ Section 48 computation with stepped cost.
☐ FA 2024 framework applied.
☐ Choice option for immovable pre-23-7-2024.
☐ Reinvestment exemptions.
☐ ITR Schedule CG.
☐ Documentation 7 years.
☐ Chain of title preserved.
☐ Section 273B defence.
☐ Section 270A bona-fide.
☐ Annual FA update.
☐ Client briefing on stepped basis.
CROSS-REFERENCES
▸ Section 2(14) — Capital asset.
▸ Section 2(42A) — Holding period.
▸ Section 2(47) — Transfer.
▸ Section 45 — Charge.
▸ Section 47 — Carve-outs.
▸ Section 48 — Computation.
▸ Section 49 — THIS SECTION.
▸ Section 50 — Depreciable assets.
▸ Section 55 — Cost / FMV / improvement.
▸ Section 55(2)(b) — FMV election.
▸ Section 56(2)(x) — Gift framework.
▸ Section 64(2) — HUF impressment.
▸ Section 111A / 112 / 112A — Rates.
▸ Hindu Succession Act, 1956.
▸ Indian Succession Act, 1925.
▸ Indian Trusts Act, 1882.
▸ Companies Act, 2013 — Amalgamation framework.
▸ Income-tax Act, 2025 — Section 49 (successor), operative 1-4-2026.
▸ Income-tax Act, 2025 — Section 536 (saving).