Section 55 is the definitional anchor for cost of acquisition and cost of improvement — the two key deductibles under section 48. Its structure: (a) Section 55(1)(b) — cost of improvement definitions; (b) Section 55(2) — cost of acquisition definitions with sub-clauses for different asset categories.
Section 55(2)(a)(i) — for self-generated goodwill / trademark / brand name / right to manufacture / tenancy rights / stage carriage permits / loom hours — cost is NIL where assessee created the asset (not purchased). This was the legislative response to the B.C. Srinivasa Setty (1981) 128 ITR 294 (SC) decision — which held that self-generated goodwill could not be taxed because computation under s. 48 failed. Section 55(2)(a)(i) deems cost as NIL to preserve the charge.
Section 55(2)(b) FMV election — for assets acquired before 1-4-2001 (post FA 2017 base year shift), taxpayer may elect to use the FMV on 1-4-2001 as cost instead of actual cost. This is structurally beneficial where the asset's FMV had appreciated significantly between acquisition and 1-4-2001. Registered valuer's report essential for FMV determination.
Section 55(2)(b)(ii) extends FMV election to s. 47 / s. 49 carve-out acquisitions — where assessee received via gift / inheritance and previous owner acquired pre-1-4-2001, FMV election available.
Cost of improvement under section 55(1)(b) — only capital expenditure on ADDITIONS / ALTERATIONS qualifies. Pre-1-4-2001 improvement is ignored (FA 2017 base year shift); only post-1-4-2001 improvement counts. This was structurally restrictive.
FA 2024 abolition of indexation does NOT change section 55 cost definitions; the cost-of-acquisition mechanism continues. What changes is the s. 48 indexation framework (or absence thereof) applied to the section 55 cost.
The transition to the Income-tax Act, 2025 preserves section 55 architecture.
▸ 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 55 — 'Cost of acquisition and cost of improvement' — Chapter IV-D.
02. Sub-section structure
(1) Cost of improvement; (2) Cost of acquisition; multiple specialised sub-clauses.
03. Operative trigger
Determination of cost for s. 48 / s. 49 computation.
04. Persons affected
All transferors of capital assets.
05. Time anchor — PY / AY
Cost fixed at acquisition; FMV election option.
06. Income anchor
Operative for capital gains computation.
07. Residential-status nexus
Standard.
08. Rate / charge mechanism
Indirect through s. 48 computation.
09. TDS / TCS interaction
Standard.
10. Advance-tax obligation
Standard.
11. Presumptive provisions
N/A.
12. Exemption / deduction mechanism
Section 55 IS the cost-quantification mechanism.
13. Refund / credit
Standard.
14. Return / disclosure reporting
ITR Schedule CG — cost working.
15. Penalty exposure
Section 270A on FMV mis-claim.
16. Prosecution exposure
Section 277.
17. Cross-statute interplay
Stamp Acts; Valuation Officer framework; Companies Act.
18. Repeal & saving — 1961 → 2025
Preserved.
HISTORICAL CONTEXT
Section 55 is the definitional anchor for cost of acquisition and cost of improvement — the two key deductibles under section 48. Its structure: (a) Section 55(1)(b) — cost of improvement definitions; (b) Section 55(2) — cost of acquisition definitions with sub-clauses for different asset categories.
Section 55(2)(a)(i) — for self-generated goodwill / trademark / brand name / right to manufacture / tenancy rights / stage carriage permits / loom hours — cost is NIL where assessee created the asset (not purchased). This was the legislative response to the B.C. Srinivasa Setty (1981) 128 ITR 294 (SC) decision — which held that self-generated goodwill could not be taxed because computation under s. 48 failed. Section 55(2)(a)(i) deems cost as NIL to preserve the charge.
Section 55(2)(b) FMV election — for assets acquired before 1-4-2001 (post FA 2017 base year shift), taxpayer may elect to use the FMV on 1-4-2001 as cost instead of actual cost. This is structurally beneficial where the asset's FMV had appreciated significantly between acquisition and 1-4-2001. Registered valuer's report essential for FMV determination.
Section 55(2)(b)(ii) extends FMV election to s. 47 / s. 49 carve-out acquisitions — where assessee received via gift / inheritance and previous owner acquired pre-1-4-2001, FMV election available.
Cost of improvement under section 55(1)(b) — only capital expenditure on ADDITIONS / ALTERATIONS qualifies. Pre-1-4-2001 improvement is ignored (FA 2017 base year shift); only post-1-4-2001 improvement counts. This was structurally restrictive.
FA 2024 abolition of indexation does NOT change section 55 cost definitions; the cost-of-acquisition mechanism continues. What changes is the s. 48 indexation framework (or absence thereof) applied to the section 55 cost.
The transition to the Income-tax Act, 2025 preserves section 55 architecture.
FINANCE ACT AMENDMENT TIMELINE
■ FA 1962 — Section 55 came into force.
■ FA 1982 — Self-generated goodwill nil cost framework (post B.C. Srinivasa Setty).
■ FA 1992 — Section 55(2)(b) FMV election base 1-4-1981.
■ FA 2017 — Base year shifted to 1-4-2001 (s. 55(2)(b) election extended).
■ FA 2018 — Section 112A grandfathering provisions for listed equity (parallel).
■ FA 2024 — Indexation abolition (cost definitions preserved).
■ FA 2025 — Cosmetic.
■ Income-tax Act, 2025 — Section 55 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 — Section 55(2)(b) FMV election (pre-1-4-2001)
Facts. A inherited property from grandfather; original purchase 1990 (Rs 10 L); FMV 1-4-2001 Rs 25 L. A sells PY 2024-25 for Rs 1.5 cr.
Computation.
S. 49(1)(iii) — Inherited cost basis = grandfather's cost.
S. 55(2)(b)(ii) — FMV election available (pre-1-4-2001 acquisition).
Option (a) — Cost Rs 10 L (no indexation post-23-7-2024 under FA 2024).
Option (b) — FMV 1-4-2001 Rs 25 L (no indexation).
FA 2024 immovable property choice — 12.5% no indexation OR 20% indexed.
Higher cost (FMV Rs 25 L) preferred under 12.5% framework.
LTCG = Rs 1.5 cr − Rs 25 L − transfer expenses.
Result. Section 55(2)(b) FMV election preserves stepped-up cost for old assets.
Illustration — Illustration 2 — Self-generated goodwill (s. 55(2)(a)(i))
Facts. B sells his proprietary business including self-generated goodwill Rs 50 L.
Computation.
S. 55(2)(a)(i) — Self-generated goodwill cost = NIL.
LTCG on goodwill = Rs 50 L − Nil = Rs 50 L.
Pre-FA 1982 — B.C. Srinivasa Setty held no CG; FA 1982 deemed nil cost.
FA 2024 — 12.5% rate on Rs 50 L = Rs 6.25 L + cess.
Result. Section 55(2)(a)(i) preserves the charge on self-generated intangibles.
Illustration — Illustration 3 — Purchased goodwill
Facts. C buys goodwill of a business from previous owner D for Rs 30 L; later sells for Rs 80 L.
Computation.
S. 55(2)(a)(i) — Purchased goodwill cost = purchase price Rs 30 L.
LTCG = Rs 80 L − Rs 30 L = Rs 50 L.
Tax per s. 112 framework.
Result. Purchased goodwill — actual cost; self-generated — nil.
Illustration — Illustration 4 — Cost of improvement
Facts. D purchased property 2005 (Rs 50 L); spent Rs 15 L improvement 2018; sells PY 2024-25 for Rs 1.5 cr.
Computation.
S. 55(1)(b)(2)(ii) — Improvement post acquisition counted.
Total cost = Rs 50 L (original) + Rs 15 L (improvement) = Rs 65 L.
Pre-23-7-2024 transfer — indexation on both.
Post-23-7-2024 — no indexation; choice option.
LTCG = Rs 1.5 cr − Rs 65 L − transfer expenses.
Result. Cost of improvement adds to acquisition cost; preserve invoices.
Illustration — Illustration 5 — FMV election dispute (s. 55A reference)
Facts. E elects FMV 1-4-2001 Rs 50 L; AO disputes, refers to Valuation Officer; VO determines FMV Rs 30 L.
Computation.
S. 55A — AO can refer to Valuation Officer where FMV claim doubtful.
VO's report binding subject to challenge.
If VO determines lower FMV → AO uses lower.
E's defence — produce registered valuer's report at FMV election.
Discrepancy challengeable in appeal.
Result. Section 55A valuation-officer reference is AO's tool; preserve registered-valuer documentation.
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. Identify cost components
Acquisition + improvement.
Step 2. Verify mode of acquisition
Direct purchase OR s. 47 / s. 49 carve-out.
Step 3. Apply s. 55(2)(a)(i) for self-generated assets
Nil cost; preserve charge.
Step 4. Apply s. 55(2)(b) FMV election for pre-1-4-2001 assets
Registered valuer's report.
Step 5. Apply s. 49 stepped cost for carve-out acquisitions
Previous owner's cost.
Step 6. Include cost of improvement
Post-1-4-2001 capital expenditure.
Step 7. Apply FA 2024 indexation framework
Pre/post 23-7-2024 distinction.
Step 8. Section 50 depreciable adjustment
If applicable.
Step 9. Section 55A valuation officer
Where dispute.
Step 10. Compute aggregate cost
For s. 48 use.
Step 11. Apply transfer expenses
Section 48(i).
Step 12. Compute capital gain
s. 48 mechanism.
Step 13. Apply applicable rate
s. 111A / 112 / 112A / FA 2024.
Step 14. ITR Schedule CG
Detailed cost working.
Step 15. Documentation 7 years
Original purchase + improvement invoices + FMV reports.
PRACTITIONER CHECKLIST
☐ Cost components identified.
☐ Mode of acquisition.
☐ Section 55(2)(a)(i) self-generated nil cost.
☐ Section 55(2)(b) FMV election (pre-1-4-2001).
☐ Registered valuer's report for FMV.
☐ Section 49 stepped basis (carve-outs).
☐ Cost of improvement post-1-4-2001.
☐ FA 2024 indexation framework.
☐ Section 50 depreciable adjustment.
☐ Section 55A reference defence.
☐ Aggregate cost computed.
☐ Transfer expenses (s. 48(i)).
☐ Capital gain computed.
☐ Applicable rate (s. 111A / 112 / 112A).
☐ ITR Schedule CG.
☐ Documentation 7 years.
☐ Section 273B defence.
☐ Annual FA update.
☐ Client briefing on FMV election.
CROSS-REFERENCES
▸ Section 2(14) — Capital asset.
▸ Section 2(42A) — Holding period.
▸ Section 45 — Charge.
▸ Section 47 — Carve-outs.
▸ Section 48 — Computation.
▸ Section 49 — Cost basis carry-over.
▸ Section 50 — Depreciable.
▸ Section 50A / B / C / CA / D — Specialised.
▸ Section 55 — THIS SECTION.
▸ Section 55A — Valuation officer reference.
▸ Section 56(2)(x) — Gift framework.
▸ Section 111A / 112 / 112A — Rates.
▸ Section 270A — Penalty.
▸ Rule 11U / 11UA / 11UAA — FMV.
▸ Wealth Tax Act, 1957 (repealed; legacy valuations preserved).
▸ B.C. Srinivasa Setty (1981) — Foundational on cost / charge interplay.
▸ Income-tax Act, 2025 — Section 55 (successor), operative 1-4-2026.
▸ Income-tax Act, 2025 — Section 536 (saving).