“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

Mukesh Vaikunthlal Mehta, Mumbai vs. Income Tax Officer Ward 34(2)(1), Mumbai

ITA 4669/MUM/2025[2011-12]Status: DisposedITAT Mumbai01 Jan 2026AY 2011-12

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Ms. Sailee GujrathiFor Respondent: Shri Annavaran Kosuri

Section 14(3)Section 143(1)Section 143(3)Section 147Section 148Section 50CSection 54

value of stamp duty authority) Assessee’s share 1/3rd of INR.7,03,00,000/- 2,34,33,333 Less: Indexed cost of acquisition (as per 83,23,442 computation) Long Term Capital Gain 1,51,09,891 Less: Capital gain already shown in the 9,891 computation Long Term Capital

Rina Ray, Siliguri vs. ITO, Ward 3(2), Darjeeling

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

ITA 2262/KOL/2025[2018-2019]Status: DisposedITAT Kolkata31 Dec 2025AY 2018-2019

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2262/Kol/2025 Assessment Year: 2018-2019 Rina Ray,………….………………….………...……Appellant C/O. Amit Kumar Ray, St. Josoph School Road, Matigara, Siliguri-734010, West Bengal [Pan:Bhipr4602M] -Vs.- Income Tax Officer,…………………………..…..Respondent Ward-3(2), Darjeeling, 27/19, Ajc Bose Road, Near Lal Kuthi, P.O. & P.S. Darjeeling, Darjeeling-734101, West Bengal Appearances By: Shri Sujit Basu, Advocate & Shri Rajib Mukherjee, Advocate, Appeared On Behalf Of The Assessee Shri Kallol Mistry, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: December 09, 2025 Date Of Pronouncing The Order: December 31, 2025 O R D E R

Section 148Section 45Section 50CSection 54E

sold property as on 01.04.2001 for Rs.6,00,000/- and computed her capital gain at Rs.22,51,125/- after considering the indexed cost of acquisition. The appellant had invested in REC Bond for 2 Rina Ray Rs.21,00,000/-, eligible for exemption u/s.54EC of the IT Act. After deduction

Ashok Kumar Khathuria, 105 Kranti Kriplani Nagar vs. CIT(A), Delhi

Appeal is allowed for statistical purpose

ITA 230/IND/2025[2013-2014]Status: DisposedITAT Indore24 Dec 2025AY 2013-2014

Bench: Shri Siddhartha Nautiyal

Section 144Section 147Section 251Section 50C

erred to sustain the order passed by the Ld. A.O. by acting in a hurried manner without considering the Indexed Cost of Acquisition, Cost of Improvement, Deductions u/*s 54F of the Act, therefore, such an order is bad in law and order so passed

BHA vs. Agar Dealers Pvt Ltd, Delhivs.ITO Ward-4(1), Delhi

In the result, appeal of the assessee in ITA No

ITA 2445/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhan

Section 142(1)Section 143(1)Section 144Section 154Section 250Section 50C

that instead of rectifying the mistake, the AO simply issued a notice under section 154 of the Act on 15.09.2021 for disallowance of indexed cost of acquisition which was originally allowed at the time of passing of the assessment order. And vide order dated 16.08.2022, a demand

Pravinsinh Bhawansinh Vaghela, Gandhinagar vs. The Income Tax Officer, Ward-3, Gandhinagar

In the result, appeal of the assessee is partly allowed

ITA 829/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad18 Dec 2025AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Parimalsinh B. Parmar, ARFor Respondent: Shri B. P. Srivastava, Sr. DR

Section 143(3)Section 54BSection 54FSection 68

land as on 01.04.1981 at ₹5 per sq. meter as against ₹80 per sq. meter claimed by the assessee, and accordingly recomputed the indexed cost of acquisition. The Assessing Officer also disallowed the deduction claimed by the assessee under section 54B of the Act amounting

Priyanka Lalitkumar Raizada, Mumbai vs. DCIT Circle 42(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 4379/MUM/2025[2014-15]Status: DisposedITAT Mumbai18 Dec 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Girish Agrawalpriyanka Lalitkumar Raizada Vs Dcit Circle 42(3)(1), C/O Ca Himanshu Gandhi, 16Th Mumbai Floor, D Wing, Trade World Kautilya Bhavan, Bandra Building, Kamala Mills Compound, Kurla Complex, Bandra Lower Parel, Mumbai 400013 East, Mumbai 400051 Pan: (Aekpr3350J) Appellant Respondent Present For: Appellant By : Shri Himanshu Gandhi, Ca Respondent By : Shri Virabhadra Mahajan, Sr. Dr (Virtually Present) Date Of Hearing : 22.09.2025 Date Of Pronouncement : 18.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Cit(A), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2023-24/1058479077(1) Dated 05.12.2023 Passed Against Assessment Order U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 26.12.2016 For Ay 2014-15. 2. Grounds Taken By The Assessee Are Reproduced As Under: “1. On The Facts & Circumstances Of The Case & Law, The Ld. Cti (A) Erred In Confirming Addition Of Rs. 21,50,540/-Being Sale Proceeds Of Inherited Jewellery As Unexplained Cash Credits U/S 68 Of The Income Tax Act, 1961. 2

For Appellant: Shri Himanshu Gandhi, CAFor Respondent: Shri Virabhadra Mahajan, Sr. DR

Section 143(3)Section 234BSection 271(1)(c)Section 68

assessee took the value of 4 ITA No.4379/MUM/2025 AY: 2014-15 Priyanka Lalitkumar Raizada jewellery contained in this valuation report to arrive at Indexed Cost of Acquisition. Assessee also furnished copies of sales invoices which reflected items sold by her and matched with the items listed in the valuation report

DCIT Circle-14(2), New Delhi vs. Meenu Shukla, Noida

In the result, the appeal of the Revenue is dismissed

ITA 175/DEL/2020[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2015-16] Deputy Commissioner Of Ms. Meenu Shukla, Income Tax, Circle-14(2), C-35, Sector-30, Room No.323, Cr Building, Vs Gautam Budh Nagar, Noida, I.P. Estate, New Delhi-110002 Uttar Pradesh-201301 Pan-Afyps8002B Appellant Respondent Assessee By Shri Ruchesh Sinha, Adv. Ms. Monalisha Maity, Adv. Revenue By Ms. Monika Singh, Cit-Dr Date Of Hearing 28.10.2025 Date Of Pronouncement 17.12.2025

Section 143(3)Section 2(47)Section 50CSection 54

Rs.2,42,65,406/- (taking full value of consideration as per section 50C of the Act at Rs.2,77,24,000/-, against the indexed cost of acquisition of Rs.34,58,594/-). The appellant claimed exemption u/s 54 of the Act for Rs.2,22,50,000/-, shown as reinvestment for purchase

Income Tax Officer, Kautilya Bhawan Bkc Kurla vs. Godrej Agrovet Limited, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 2026/MUM/2025[2016-17]Status: DisposedITAT Mumbai16 Dec 2025AY 2016-17

Bench: Ms Suchitra Kamble & Shri Girish Agrawalthe Income Tax Officer, Godrej Agrovet Limited, Vs. Kautilya Bhavan, Godrej One, Bkc Kurla, 3Rd Floor Pirojshanagar, Mumbai-400051 E.E, Highway, Vikhroli So Mumbai, Mumbai-400079. [Pan: Aaacg0617Q] (Appellant) .. (Respondent) Appellant By : Shri Krishna Kumar, Sr. Dr Respondent By: Shri Nitesh Joshi, Ar Date Of Hearing 18.09.2025 Date Of Pronouncement 16.12.2025 O R D E R Per Suchitra Kamble:

For Appellant: Shri Krishna Kumar, Sr. DRFor Respondent: Shri Nitesh Joshi, AR

Section 112Section 112(1)Section 112(1)(c)Section 133(6)Section 195Section 201Section 201(1)Section 206ASection 48

provisions of clause (ii) shall have effect as if for the words “cost of acquisition” and “cost of any improvement”, the words “indexed cost of acquisition” and “indexed cost of any improvement” had respectively been substituted. In the present case the contention of the Ld.DR that the first proviso

ITO (International Taxation)-1, Hyderabad vs. Kesava Kumar Kunapureddy, Hyderabad

In the result, the appeal of the Revenue is dismissed

ITA 937/HYD/2025[2018-19]Status: DisposedITAT Hyderabad12 Dec 2025AY 2018-19

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 139(1)Section 54ESection 54F

Before the Ld. CIT(A), the assessee submitted that, he has computed long-term capital gain derived from sale of property after claiming indexed cost of acquisition, deduction under Section 54EC of Rs. 50,00,000/- for investment in REC Bonds and also claimed deduction

Thirumal Arun Mohan Dass, Puducherry vs. The Assistant Commissioner of Income Tax, Circle 1, Puducherry

In the result, the appeal of the assessee for A

ITA 2213/CHNY/2025[2020-21]Status: DisposedITAT Chennai12 Dec 2025AY 2020-21

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2212 & 2213/Chny/2025 िनधा%रण वष% /Assessment Years: 2015-16 & 2020-21

For Appellant: Mr. V. Meenakshi Sundar, C.A *+For Respondent: Ms. Babitha, JCIT

Section 148Section 250

Income offered @8% 12,10,509 2 Capital Gains Sale consideration [S.No.(h)] 75,50,000 Less: Indexed cost of Acquisition 70,99,246 Long Term Capital Gain 4,50,754 3. Other Sources i Interest income [S.No.(a) & (b)] 1,33,722 ii Other Receipts [S.No

Thirumal Arun Mohan Dass, Puducherry vs. The Assistant Commissioner of Income Tax, Circle 1, Puducherry

In the result, the appeal of the assessee for A

ITA 2212/CHNY/2025[2015-16]Status: DisposedITAT Chennai12 Dec 2025AY 2015-16

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2212 & 2213/Chny/2025 िनधा%रण वष% /Assessment Years: 2015-16 & 2020-21

For Appellant: Mr. V. Meenakshi Sundar, C.A *+For Respondent: Ms. Babitha, JCIT

Section 148Section 250

Heta Rawal Legal Heir of Late Shri Shailesh Induprasad Rawal, Vadodara vs. The Dy.CIT, Circle-1(1)(1), Vadodara

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

ITA 281/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad11 Dec 2025AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2013-14

Section 143(3)Section 250Section 54F

Page 2 of 5 CASS. In the return, the assessee had disclosed Long Term Capital Gain (LTCG) of Rs.75,83,600/- after claiming indexed cost of acquisition and exemption under Section 54F of the Act. In the course of assessment, the Assessing Officer had treated the sale consideration ... asset as income from business and accordingly deduction claimed under Section 54F of the Act as well as deduction for indexed cost of acquisition was denied. The assessment was completed under Section 143(3) of the Act on 29.01.2016 at a total income of Rs.1,67,53,350/-. 3. Aggrieved

Jhansi Lakshmi Ramanadham, Hyderabad vs. ITO., Ward-8(1), Hyderabad

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

ITA 886/HYD/2025[2015-16]Status: DisposedITAT Hyderabad10 Dec 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.886/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Smt. Jhansi Lakshmi Vs. Income Tax Officer Ramanadham Ward 8 (1) Hyderabad Hyderabad Pan:Acbpr3566K (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate S. Sandhya राज" व "ारा/Revenue By:: Shri Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 04/12/2025 घोषणा की तारीख/Pronouncement: 10/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Smt. Jhansi Lakshmi Ramanadham, (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 30.05.2024 For The A.Y 2015-16. 2. At The Outset, It Is Seen That There Is A Delay Of 292 Days In Filing The Present Appeal Before This Tribunal. The Assessee Has Filed An Affidavit Explaining The Reasons For The Delay. The Learned Authorized Representative (“Ld. Ar”) Submitted That The Assessee Is Page 1 Of 12

For Appellant: Advocate S. SandhyaFor Respondent: : Shri Arun Kumar, Sr. DR

said property and accordingly admitted her share of capital gain. In her computation, the assessee claimed selling expenses of Rs.14,54,022/-, indexed cost of acquisition of Rs.10,49,953/- and indexed cost of improvement amounting to Rs.3,04,99,447/-. She thus worked out her share of capital gain

ACIT., Circle-5(1), Hyderabad vs. Pragnapur Developers Private Limited, Hyderabad

Accordingly, the grounds Nos. 1 to 12 are partly allowed

ITA 441/HYD/2025[2022-23]Status: DisposedITAT Hyderabad10 Dec 2025AY 2022-23

Bench: Us:

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

return of income had declared sale of immovable property for a consideration of Rs. 20,56,80,640/-, and after reducing indexed cost of acquisition and cost of improvement, disclosed “Long term capital gain” (LTCG) of Rs. 4,21,57,691/-. The AO called upon the assessee company to furnish

Eris Lifesciences Limited, Ahmedabad vs. NFAC, Delhi (Present Jurisdiction- the Dy. CIT, Circle-2(1)(1)), Ahmedabad

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 915/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR

Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

accordingly directed exclusion of ₹19,66,92,733 from book profit. On the assessee’s further additional claim regarding reduction of indexed cost of acquisition in computation of MAT, the CIT(A) held that MAT computation under section 115JB must follow the Companies Act framework and Part II/III of Schedule ... rival contentions and perused the material on record. The issue for adjudication is whether the assessee is entitled to the benefit of indexed cost of acquisition while computing book profit under section 115JB of the Act in respect of long-term capital gains arising from transfer of capital assets

Eris Lifesciences Limited, Ahmedabad vs. NFAC, Dehi (Present Jurisdiction- the Dy. CIT, Circle-2(1)(1), Ahmedabad

Appeal are dismissed

ITA 914/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2021-22

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Vartik Choksi, ARFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR

Section 115JSection 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

accordingly directed exclusion of ₹19,66,92,733 from book profit. On the assessee's further additional claim regarding reduction of indexed cost of acquisition in computation of MAT, the CIT(A) held that MAT computation under section 115JB must follow the Companies Act framework and Part II/III of Schedule ... rival contentions and perused the material on record. The issue for adjudication is whether the assessee is entitled to the benefit of indexed cost of acquisition while computing book profit under section 115JB of the Act in respect of long-term capital gains arising from transfer of capital assets

Eris Lifesciences Limited, Ahmedabad vs. NFAC, Delhi (Present Jurisdiction - the Dy. CIT, Circle-2(1)(1)), Ahmedabad

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 913/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2020-21

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR

Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

Eris Lifesciences Limited, Ahmedabad vs. NFAC, Dehi (Present Jurisdiction- the Dy.CIT, Circle-2(1)(1)), Ahmedabad

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 912/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR

Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

DCIT Circle-2(1)(1), Ahmedabad, Vejalpur vs. Eris Lifesciences Limited Shivarth Ambit, Bodakdev Ahmedabad

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 850/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR

Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80

Dcie Circle-2(1)(1), Ahemdabad, Vejalpur vs. Eris Lifesciences Limited Shivarth Ambit, Bodakdev Ahmedabad

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

ITA 849/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2021-22

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DRFor Respondent: Shri R P Rastogi, CIT-DR & Shri Abhijit, Sr. DR

Section 14ASection 36(1)(va)Section 37(1)Section 43BSection 80