“indexed cost of acquisition”

Capital GainsSection 48Section 48674 judgments

The decision most relied on for indexed cost of acquisition is CIT v. Manjula J. Shah (355 ITR 474), cited in 113 judgments on BharatTax.

Leading authorities on indexed cost of acquisition

CIT v. Manjula J. Shah

355 ITR 474 · 2013 · High Court

113

citing judgments

For capital assets acquired by gift or will, the indexed cost of acquisition under Section 48 is computed with reference to the year the previous owner first held the asset. The period of holding for determining if an asset is long-term also includes the previous owner's holding period, as per Section 2(42A).

PCIT v. Vembu Vaidyanathan

108 Taxmann.com 339 · 2019 · Supreme Court

citing judgments

A Special Leave Petition filed by the Income Tax Department against a decision concerning the computation of capital gains or related issues was dismissed by the Supreme Court.

Karnataka State Industrial Infrastructure Development Corporation Ltd. v. DCIT

76 Taxmann.com 360 · 2016 · ITAT

citing judgments

The expression 'any income' in Section 10(38) refers to long-term capital gains computed under Section 48, which includes the indexed cost of acquisition. This principle applies when computing book profits under Section 115JB.

Bharat Hari Singhania v. CWT

19 SOT 612 · 2008 · High Court

citing judgments

While the case involves a reference to "fresh tangible material", "valuation of shares", "going concern", and "indexed cost of acquisition", the provided passages do not clearly articulate the specific holding of Bharat Hari Singhania v. CWT.

Mahindra & Mahindra Ltd. v. DCIT, 313 ITR (AT) 263 (SB)

110 ITD 59 · 2008 · ITAT

citing judgments

The Assessing Officer cannot improve his assessment by adopting a new theory during reassessment proceedings.

CIT v. Shri Hariram Hotels Pvt. Ltd.

325 ITR 136 · 2010 · High Court

citing judgments

Interest paid on loans taken for acquiring an asset is includible in the cost of acquisition for computing capital gains. This interest is also eligible for indexation benefit.

Judgments citing indexed cost of acquisition

Vijay Spinning Mills Limited, Krishna District vs. Assistant Commissioner of Income Tax, Circle-1(1), Vijayawada

In the result, appeal of the assessee is allowed for statistical purpose

ITA 181/VIZ/2022[2013-14]Status: DisposedITAT Visakhapatnam21 Apr 2023AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.181/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2013-14) Vijay Spinning Mills Ltd., Vs. Asst.Commissioner Of 5-111-10, Vsm Quarters Income Tax Ganguru, Penamaluru Mandal Circle-1(1) Krishna Dist. Vijayawada [Pan : Aaacv7518B] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : None प्रत्यधथी की ओर से / Respondent By : Shri O.N.Hari Prasada Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 07.03.2023 घोर्णध की तधरीख/Dt. Of Pronouncement : 21.04.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: This Appeal Is Filed By The Assessee Against The Order Of Commissioner Of Income Tax (Appeals) [Cit(A)], National Faceless Appeal Centre (Nfac), Delhi Vide Din & Order No.Itba/Nfac/S/250/2022-23/1044219637(1) Dated 28.07.2022 Arising Out Of The Orders Passed U/S 271(1)(C) Of The Income Tax Act, 1961 (In Short “Act”) Dated 26.03.2022 For The Assessment Year (A.Y.) 2013-14. 2

For Appellant: NoneFor Respondent: Shri O.N.Hari Prasada Rao, DR

Section 115JSection 143(3)Section 154Section 250Section 271(1)(c)Section 275(1)(a)

merely a reclassification from revenue expenditure to capital expenditure. 9. Without prejudice to the above grounds, the Ld.AO erred by not considering the Indexed cost of acquisition in computing the penalty on the long term capital gain of Rs.1,86,98,968/-. 10. Without prejudice to the above grounds

Deputy Commissioner of Income Tax (Large Taxpayer Unit) - 2, Mumbai vs. Reliance Industries Ltd, Mumbai

In the result, additional ground number 6 raised by the assessee which is held by the coordinate bench in miscellaneous application order as not decided is now adjudicated and allowed

ITA 136/MUM/2018[2013-14]Status: DisposedITAT Mumbai20 Apr 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Asst. Commissioner Of Income Tax, Reliance Industries Limited Large Taxpayer Unit, 3Rd Floor, Maker Chamber-Iv 29Th Floor, Center No.1, World Vs. 222, Nariman Point, Trade Centre, Mumbai-400 021 Cuffe Parade, Mumbai-400 005 (Appellant) (Respondent) Pan No. Aaacr5055K Asst. Commissioner Of Income Tax, Reliance Industries Limited Large Taxpayer Unit, 3Rd Floor, Maker Chamber-Iv 29Th Floor, Center No.1, World Vs. 222, Nariman Point, Trade Centre, Mumbai-400 021 Cuffe Parade, Mumbai-400 005 (Appellant) (Respondent) Assessee By : Shri Madhur Agrawal, Advocate Shri Nimesh Vora & Ms Moksha Mehta, Cas, Ars' Revenue By : Shri Rajesh Damor, Cit Dr

For Appellant: Shri Madhur Agrawal, AdvocateFor Respondent: Shri Rajesh Damor, CIT DR

loss arising on the transfer of the above shares. Accordingly, we direct the assessee to substantiate sale consideration, cost of acquisition and indexed cost of acquisition before the learned assessing officer and its computation of capital ITA Nos. 7299/Mum/2017 & 136/Mum/2018 Reliance Industries Limited; A.Y. 13-14 gain/loss. The learned assessing

Reliance Industries Limited, Mumbai vs. Assistant Commissioner of Income Tax- Large Taxpayer Unit, Mumbai

In the result, additional ground number 6 raised by the assessee which is held by the coordinate bench in miscellaneous application order as not decided is now adjudicated and allowed

ITA 7299/MUM/2017[2013-14]Status: DisposedITAT Mumbai20 Apr 2023AY 2013-14

For Appellant: Shri Madhur Agrawal, AdvocateFor Respondent: Shri Rajesh Damor, CIT DR

Pramod Modi, Dholpur (Raj.) vs. Income Tax Officer, Ward - 4, Bharatpur

In the result, appeal of the assessee is allowed for statistical purpose

ITA 193/JPR/2021[2011-12]Status: DisposedITAT Jaipur20 Apr 2023AY 2011-12

Bench: Issuance Of Notice U/S 148 & Acted Only On Borrowed Satisfaction Which Is Not Permitted In Law. Therefore, The Action Of The Ld. Ao In Reopening The Assessment U/S 148 Deserves To Be Quashed.

For Appellant: Sh. Jaideep Malik (Adv.)For Respondent: Smt Chanchal Meena (Addl. CIT)

Section 144Section 147Section 148

account of capital gain, and that too only to the extent of assessee's 1/12 share of sale consideration reduced by the indexed cost of acquisition. 3 Pramod Modi vs. ITO 5. That the appellant craves the right to add, delete, amend or abandon any of the grounds of appeal

Income Tax Officer (It)-3(2)(1), Mumbai vs. Rustom Fali Mehta, Mumbai

In the result, the cross objection filed by the assessee is partly allowed for statistical purposes

ITA 54/MUM/2023[2016-17]Status: DisposedITAT Mumbai18 Apr 2023AY 2016-17

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Madhur Agarwal a/wFor Respondent: Shri Soumendu Kumar Dash

Section 250

right in claiming the cost of his 15% undivided share in the said property as on 01/04/1981 and thereafter to apply for indexed cost of acquisition to ascertain the indexed cost of acquisition in December 2015, while computing capital gain for A.Y.2016-17, because the property was transferred to him vide ... Circular No.636 had held that while computing capital gains arising of transfer of capital asset acquired by the assessee under the will, the indexed cost of acquisition has to be computed with respect to the year in which the previous owner first held the asset and not in the year

Gopalbhai Bachubhai Senjalia, Mumbai vs. ITO, Ward 3(2), Kalyan

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 349/MUM/2023[2012-13]Status: DisposedITAT Mumbai18 Apr 2023AY 2012-13

Bench: Shri S. Rifaur Rahman, Hon'Blegopalbhai Bachubhai Senjalia V. Ito, Ward 3(2) 102, Tulsi Dhara, Gokul Nagar 2Nd Floor, Rani Mansion Khadak Pada, Kalyan (W) Murbad Road, Kalyan (W) Thane- 421301 Thane- 421301 Pan: Actps3399H (Appellant) (Respondent)

Section 147Section 148Section 2(14)(ii)Section 50CSection 50C(2)

sale of agricultural land bearing survey no. 161 Pt. 1 at Pedhala Village, Tal. Jetpur, Dist. Rajkot, Gujarat, without granting deduction for indexed cost of acquisition of the said land and erroneously computing the long term capital gains. 8. The appellant craves leave to add, alter, amend and/or vary

DCIT, CC, Gzbd vs. Anjali Mittal, Gzbd

In the result, appeal of the Revenue is dismissed

ITA 1809/DEL/2021[2018-19]Status: DisposedITAT Delhi06 Apr 2023AY 2018-19

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year: 2018-19 Dy. Commissioner Of Vs. Smt. Anjali Mittal, Income Tax, B-7, Ashok Nagar, Central Circle, Ghaziabad-201 001. Ghaziabad. Pan Aigpm4257R (Appellant) (Respondent)

For Appellant: Shri Somil Agarwal, AdvFor Respondent: Shri Kanav Bali, Sr. DR

Section 133ASection 54FSection 54F(1)(b)Section 69A

found that the appellant had sold immovable property on 03.03.2018 at Rs. 58,50,000/- and for computation of capital gain, she claimed Indexed Cost of Acquisition of Rs 29, 55,243/-, thus capital gain has been computed at Rs. 28,94,757/-. Further the appellant purchased a residential property

The DCIT, Cen-Circle, Thrissur vs. Sri.T.G. Chandrakumar, Thrissur

In the result, the Appeal by the Revenue is allowed on the aforesaid terms

ITA 67/COCH/2018[2008-09]Status: DisposedITAT Cochin03 Apr 2023AY 2008-09

Bench: Shri Sanjay Arora (Accountant Member), Shri Sandeep Gosain (Judicial Member)

For Appellant: Smt. J.M. Jamuna Devi, Sr. DRFor Respondent: Shri C.B.M. Warrier, FCA

Section 132Section 153CSection 268A

term capital gain was accordingly assessed by reducing from the sale consideration of Rs. 620.19 lacs, i.e., @ Rs. 2.24 lac per cent, the indexed cost of acquisition for each of the four sellers, at Rs. 6,13,25,694 (Rs. 613.26 lacs). The same stands deleted in first appeal

Siva Rama Krishna Rao Nutakki, Visakhapatnam vs. Income Tax Officer, Ward-2(1), Visakhapatnam

In the result, appeal filed by the assessee is dismissed

ITA 180/VIZ/2022[2019-20]Status: DisposedITAT Visakhapatnam31 Mar 2023AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Sri ON Hari Prasada Rao

Section 143(3)Section 195Section 234BSection 234C

During the year, the assessee admitted capital gain of Rs. 6,68,93,262/- after claiming brokerage, indexed cost of acquisition and the cost of improvements on the said sale of immovable property and filed the return of income on 29/02/2020 admitting income of Rs. 6,72,20,240/- which

Mr. Gurvantlal Maganlal Naik, Na vs. Arivs.ITO, Ward-2, Navsari

ITA 96/SRT/2018[2013-14]Status: DisposedITAT Surat21 Mar 2023AY 2013-14

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.96/Srt/2018 "नधा"रण वष"/Assessment Year: (2013-14) (Physical Hearing) Gunvantlal Maganlal Naik, Vs. The Ito, Ward-2, C/O. Bipinbhai M. Naik, Navsari. Near Aahirwad, Nr. Cricket Ground, At. Chhapra, Navsari – 396445. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apipn3403R

Section 142(1)Section 143(1)Section 143(2)Section 143(3)

value on the basis of valuation report, cost of the property is at Rs.10,97,731/- as on 01.04.1981. The assessee has claimed indexed cost of acquisition at Rs.94,12,668/- at a very higher side as compared to the market value. Therefore, a show cause notice was issued ... computation of capital gain made by another co-owner of the land, Mr. Manojkumar Gunvantlal Naik, wherein the co-owner has taken an indexed cost of acquisition at the rate of Rs.175 per square meter which is placed at paper book page no.150, therefore, Ld. Counsel contended that assessee should

Yadla Srinivasa Rao, Vijayawada vs. The Income Tax Officer, Ward-3(2), Vijayawada

In the result, appeal of the assessee is dismissed

ITA 78/VIZ/2021[2011-12]Status: DisposedITAT Visakhapatnam17 Mar 2023AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.78/Viz/2021 (ननधधारण वर्ा / Assessment Year : 2011-12) Yadla Srinivasa Rao Vs. Income Tax Officer D.No.20-04-190/7A Ward-3(2) Basavataraka Nagar Vijayawada Ayodhya Nagar Vijayawada [Pan : Abfpy5447F] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri M.Madhusudan, ARFor Respondent: Shri O.N.Hari Prasada Rao, DR

Section 139Section 148Section 2(47)(v)Section 50C

well as the Ld.CIT(A) has rightly taxed the capital gains in the hands of the assessee after allowing deduction of indexed cost of acquisition of Rs.6,54,090/-. Hence, the grounds raised by the assessee are dismissed. 9. Ground No.4 is related to estimation of the value ... section 50C of the Act, the AO has correctly computed the capital gains against the sale consideration of Rs.20,00,000/- after allowing indexed cost of acquisition at Rs.6,54,090/- and arrived at the long term capital gains of Rs.13,45,910/-. For the sake of clarity, the provisions

ACIT Circle-20(2), New Delhi vs. Sadhna Aggarwal, Delhi

In the result, the appeal of the Revenue is dismissed

ITA 6620/DEL/2019[2016-17]Status: DisposedITAT Delhi15 Mar 2023AY 2016-17

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Shri Anuj Jain, CAFor Respondent: Shri Abhishek Kumar, CIT-DR

Section 143(3)

Rs.1,35,930/- as part of its cost of acquisition. To justify the cost of acquisition for the purposes of determination of indexed cost of acquisition and eventual capital gains, the assessee pointed out before the Assessing Officer that there are three types of cost of acquisition in the case

James Kudakuthiyil Chacko, Kerala vs. DCIT, International Taxation Cricle, Trivandrum

In the result, appeal is allowed for statistical purposes

ITA 863/COCH/2022[2012-13]Status: DisposedITAT Cochin08 Mar 2023AY 2012-13

Bench: Shri George George K & Ms. Padmavathy Sassessment Year :2012-13 James Kudakuthiyil Chacko, Dcit, Vs. Kbc Enclaves, International Taxation Circle, Laikadu, Perunna P.O. Trivandrum. Changanacherry, Kerala – 686 102. Pan :Ajbpc 2186 R Assessee Respondent

For Appellant: Shri. R. Krishnan,CAFor Respondent: Smt. J M Jamuna Devi, Sr. AR

Section 131Section 5(1)Section 69

purpose of computing the capital gains in the hands of the assessee as per below working Sale consideration Rs.7,11,65,000 Less : Indexed cost of acquisition Rs.2,57,93,665 Capital Gains Rs.4,53,71,335 6. Aggrieved, the assessee preferred appeal before the CIT(A). The assessee submitted

Sanjay Sharma, Greater Noida vs. ACIT, Noida

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 741/DEL/2022[2012-13]Status: DisposedITAT Delhi27 Feb 2023AY 2012-13

Bench: Shri Kul Bharat[Assessment Year : 2012-13] Sanjay Sharma, Vs Acit, Flat 4063, Ats Paradiso, Noida. Sec-Chi-04, Greater Noida, Gautam Budh Nagar, Uttar Pradesh-201308. Pan-Amkps9185L Appellant Respondent Appellant By Shri Jai Bhagwan Sharma, Ca Respondent By Shri Sanjay Nargas, Sr.Dr Date Of Hearing 15.02.2023 Date Of Pronouncement 27.02.2023 Order Per Kul Bharat, Jm : The Present Appeal Filed By The Assessee For The Assessment Year 2012-13 Is Directed Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (“Nfac”), Delhi Dated 23.12.2021. 2. The Assessee Has Raised Following Ground Of Appeal:- 1. “In The Instant Case The Appellant Assessee While Submitting The Income Tax Return For The Financial Year Ended On 31-03-2012 (Relevant To The Asst. Year 2012-13) Inadvertently Forgotten To Submit The Details For Claiming Exemption U/S. 54 Of The Income Tax Act, 1961 & Did Not Mentioned The Details Of Sale Of Residential House Property & Utilization Of Long-Term Capital Gain Arising Out Of Sale Of Residential House Property In The Purchase Of Another/New Residential House Property. Consequently, Income Demand Of Rs. 5,61,107/- Was Raised Against The Appellant Assessee Followed By The Penalty Proceedings U/S. 271(1)(C) Of The Income Tax Act, 1961

Section 144Section 271(1)(c)Section 54

term capital gains (LTCG) at RS.19,54,873/- on the sale proceeds of the said property at Rs. 46,65,000/-, after claiming indexed cost of acquisition. It is also seen that the assessee had purchased a residential property for a consideration of Rs.37,50,830/- on 22.05.2008, i.e., within

Smt. Ritu Singh, Delhi vs. ITO, New Delhi

In the result, appeal of the assessee is allowed

ITA 6504/DEL/2016[2012-13]Status: DisposedITAT Delhi24 Feb 2023AY 2012-13

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year: 2012-13

For Appellant: Shri Hiren Mehta, CAFor Respondent: Ms. Princy Singla, Sr. DR

Section 143(1)Section 143(3)Section 54Section 68

under:- Amount Sale consideration of property 2,40,00,000 (Flat No. 55, C-Block, Sector-44, Noida) Less: Indexed Cost of acquisition 61,46,532 _______________ Long term capital Gain 1,78,53,468.00 Less: Property purchased 1)345, Block-C, Omaxe NRI City, Greater Noida ... term capital gain is as under:- Sale consideration of property (Flat No. 55, C-Block, Sector-44, Noida) 2,40,00,000 Less: Indexed Cost of acquisition 61,46,532 ________________ Long term capital Gain 1,78,53,468.00 Less: Property purchased 1)345, Block-C Omaxe NRI City, Greater Noida

Renu Khurana, New Delhi vs. ACIT, Int.Tax 2(1)(2), New Delhi

In the result, the appeal is allowed

ITA 1368/DEL/2022[2019-20]Status: DisposedITAT Delhi17 Feb 2023AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Deyassessment Year: 2019-20 Ms. Renu Khurana, Vs. Acit, H. No. 6480, Sector C-6, Intl. Taxation -2(1)(2), Vasant Kunj, New Delhi New Delhi Pan :Bbppk6150E (Appellant) (Respondent)

Section 143(3)Section 144Section 144C(13)Section 48

Dispute Resolution Panel (DRP). 2. The dispute between the parties in the present appeal is in relation to deduction claimed on account of indexed cost of acquisition for the purpose of computing long term capital gain. AY: 2019-20 3. Briefly the facts are, the assessee is a non-resident ... registered sale deed dated 29.03.2019 for a consideration of Rs.2,10,00,000/-. After deducting an amount of Rs.2,09,54,863/- towards indexed cost of acquisition under section 48 of the Act, the assessee offered long term capital gain of Rs.45,137/- in the return of income filed

Virender Singh Tyagi, Ghaziabad vs. ITO, Ward- 2(5), Ghaziabad

In the result, the appeal of the assessee is dismissed

ITA 3600/DEL/2018[2011-12]Status: DisposedITAT Delhi15 Feb 2023AY 2011-12

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year: 2011-12

For Appellant: NoneFor Respondent: Ms. Princy Singla, Sr. DR

Section 143(1)Section 143(3)Section 54Section 54F

assessee and accordingly made an addition of Rs. 88,17,144/- as per following working:- Sale Consideration Rs. 93,13,000/- Less: Indexed cost of acquisition: The assessee has adopted circle rate of Rs. 200/- As on 1.4.1981 in respect of the land in question Whereas circle rate

Shri Tulshibhai Polabhai Sakariya, Rajkot vs. The Pr. CIT-1, Rajkot

In the result, appeal filed by assessee is allowed

ITA 93/RJT/2021[2015-16]Status: DisposedITAT Rajkot15 Feb 2023AY 2015-16

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita No. 93/Rjt/2021 िनधा"रणवष" िनधा"रणवष"/Asstt. Year:2015-16 िनधा"रणवष" िनधा"रणवष" Shri Tulsibhai Polabhai Sakariya Vs. The Pr. C.I.T, 2-Bombay Housing Society, Rajkot-1, Meghdhara, University Road, Rajkot. Opp. G. K. Dholakiya, Rajkot

For Appellant: Shri Mehul Ranpura, A.RFor Respondent: Shri Shramdeep Sinha, CIT DR

Section 143(3)Section 263Section 54F

Government approved valuer adopted the cost of acquisition as on 1st April 1981 at Rs. 740 per Sq. Mts. Accordingly, the assessee claimed indexed cost of acquisition at Rs. 3,22,04,800/- only. The assessee against the capital gain also claimed deduction under section

Kanhaiya Lal Lalwani, Jaipur vs. ITO Ward-5(1) Jaipur, Jaipur

In the result, the appeal of the assessee is allowed

ITA 364/JPR/2022[2011-12]Status: DisposedITAT Jaipur13 Feb 2023AY 2011-12

Bench: Hon’ble SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri C.P. Chawla, ITPFor Respondent: Smt. Monisha Choudhary, JCIT

also noted from the record that the assessee is not having any taxable income and the AO has not given the benefit of indexed cost of acquisition and indexed cost of improvement on the immovable property in question and thus in that eventuality the capital gain arose on the sale

Navinchandra K. Patel, Surat vs. Principle Commissioner of Income Tax -1, Surat

In the result, appeal filed by the assessee is allowed

ITA 57/SRT/2021[2015-16]Status: DisposedITAT Surat10 Feb 2023AY 2015-16

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.57/Srt/2021 Assessment Year: (2015-16) (Physical Court Hearing) Navinchandra K. Patel, Vs. The Pcit-1, Surat. 5, Kaaliytawadi Faliya, At Post Saniya Hemad, Surat-395006. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Birpp6292D (Appellant) (Respondent) Assessee By Shri Sapnesh Sheth, Ca Respondent By Shri Ritesh Mishra, Cit(Dr) Date Of Hearing 02/02/2023 10/02/2023 Date Of Pronouncement आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Appeal Filed By Assessee, Pertaining To Assessment Year (Ay) 2015-16, Is Directed Against The Order Passed By The Learned Principal Commissioner Of Income Tax, Surat (In Short “Ld. Pcit”], Under Section 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”), Dated 31.03.2021. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows: “1. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Pr. Commissioner Of Income-Tax Has Erred In Passing Revisionary Order U/S 263 Of The I.T. Act Setting Aside The Order Of Ld. Assessing Officer Passed U/S 143(3) Of The Act Dated 24.11.2017 For The Year Under Consideration Although Said Order Is Neither Erroneous Nor Prejudicial To The Interest Of Revenue. 2. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Pr. Commissioner Of Income-Tax Has Erred In Observing That Order Passed By Assessing Officer U/S 143(3) Of The Act Is Erroneous On The Ground That Indexed Cost Of Acquisition Of Property Is Under Assessed By Rs.2,12,58,035/-. 3. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Pr. Commissioner Of Income-Tax Has Erred In Observing That Order

Section 143(3)Section 263Section 54BSection 54F

erred in observing that order passed by assessing officer u/s 143(3) of the Act is erroneous on the ground that indexed cost of acquisition of property is under assessed by Rs.2,12,58,035/-. 3. On the facts and circumstances of the case as well ... meter lying in T.P. Scheme No. 52) for a sale consideration of Rs.7,78,52,500/- on 28.08.2014. The assessee calculated indexed cost of acquisition of Rs.2,23,77,267/-. The assessee had claimed deduction of Rs.3,11,41,000/- as expenses on premium for conversion of agriculture land