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“cost of improvement”

Capital GainsSection 55Section 55749 judgments

The decision most relied on for cost of improvement is CIT v. Kasturi Estates (P.) Ltd. (62 ITR 578), cited in 25 judgments on BharatTax.

Leading authorities on cost of improvement

CIT v. Kasturi Estates (P.) Ltd.
62 ITR 578 · 1966 · High Court
25
citing judgments

Expenditure incurred to improve property before sale, such as dividing land into plots and laying roads, does not constitute an adventure in the nature of trade if the primary purpose is to obtain a better price for the property.

Arunachalam v. CIT
227 ITR 222 · 1997 · Supreme Court
22
citing judgments

Expenditure incurred by an assessee to discharge a mortgage created by a previous owner is an allowable deduction in computing capital gains, as it represents the cost of acquisition or perfecting an imperfect title. The assessee's payment to clear the encumbrance is not deductible for capital gains computation.

Commissioner of Income-tax v. Miss Piroja C. Patel
242 ITR 582 · 2000 · High Court
12
citing judgments

Compensation paid to hutment dwellers for vacating land is an allowable expenditure in computing capital gains, as it relates to the transfer of the asset. Such payments are considered a cost of acquisition or improvement under Section 48 read with Section 55 of the Income-tax Act, 1961.

Naozar Chenoy v. CIT
234 ITR 95 · 1998 · High Court
11
citing judgments

Expenditure incurred to pay tenants to vacate premises, which are the subject of a sale transaction, is allowable as a deduction in computing capital gains. This is because the expenditure is directly connected to and necessary for effecting the transfer of the property.

Mahindra & Mahindra Ltd. v. DCIT, 313 ITR (AT) 263 (SB)
110 ITD 59 · 2008 · ITAT
10
citing judgments

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

Mrs. June Perrett v. Income-tax Officer
298 ITR 268 · 2008 · High Court
10
citing judgments

Payment made to secure an order of eviction and evict an unauthorized occupant can be treated as a cost of improvement.

Judgments citing cost of improvement

Shri V. Natarajan (Individual), Rasipuram vs. ACIT, Central Circle, Salem

In the result, both the appeals of assessee in ITA No

ITA 1801/CHNY/2024[2015-16]Status: DisposedITAT Chennai31 Oct 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

For Appellant: Mr.T.S. LakshmiFor Respondent: Mr.Shiva Srinivas, CIT
Section 115BSection 143(3)Section 153ASection 250Section 250(6)Section 37Section 68

were duly explained and had already been offered to tax in the return under “Income from Other Sources.” v. That the disallowance of cost of improvement was made without appreciating supporting evidence. The assessee has raised several grounds, the sum and substance of which is that

Varadappan Natarajan, Rasipuram vs. ACIT, Central Circle, Salem

In the result, both the appeals of assessee in ITA No

ITA 1535/CHNY/2024[2016-17]Status: DisposedITAT Chennai31 Oct 2025AY 2016-17

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

For Appellant: Mr.T.S. LakshmiFor Respondent: Mr.Shiva Srinivas, CIT
Section 115BSection 143(3)Section 153ASection 250Section 250(6)Section 37Section 68

were duly explained and had already been offered to tax in the return under “Income from Other Sources.” v. That the disallowance of cost of improvement was made without appreciating supporting evidence. The assessee has raised several grounds, the sum and substance of which is that

Nisha Vijay Israni, Mumbai vs. ACIT, International Taxation, Circle-1(2), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 608/BANG/2025[2022-23]Status: DisposedITAT Bangalore31 Oct 2025AY 2022-23

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: N O N EFor Respondent: Dr. Divya K.J., D.R
Section 139Section 143(1)Section 143(2)Section 143(3)

personal effect such as roof top solar plant, air conditioners, wall speakers, microwave oven etc. which the assessee had claimed as the cost of improvement. Since the assessee had made expenses of Rs.25,72,807/- towards items of personal effect, the AO accordingly disallowed the same as cost of improvement ... accordingly, we allowed this ground of appeal of the assessee. 6.3 Now with regard to disallowance of Rs.25,72,807/- claimed towards cost of improvement, the AO from the computation of income seen that the assessee made an expenses of Rs.25,72,807/- towards items of personal effect such

Vijay Lakhmichand Israni, Mumbai vs. ACIT, International Taxation, Circle-1(2), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 607/BANG/2025[2022-23]Status: DisposedITAT Bangalore31 Oct 2025AY 2022-23

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: N O N EFor Respondent: Dr. Divya K.J., D.R
Section 139Section 143(1)Section 143(2)Section 143(3)

personal effect such as roof top solar plant, air conditioners, wall speakers, microwave oven etc. which the assessee had claimed as the cost of improvement. Since the assessee had made expenses of Rs.25,72,807/- towards items of personal effect, the AO accordingly disallowed the same as cost of improvement ... accordingly, we allowed this ground of appeal of the assessee. 6.3 Now with regard to disallowance of Rs.25,72,807/- claimed towards cost of improvement, the AO from the computation of income seen that the assessee made an expenses of Rs.25,72,807/- towards items of personal effect such

Indrajeet Suresh Magar, Kolhapur vs. Income Tax Officer, Kolhapur

ITA 755/PUN/2025[2018-2019]Status: DisposedITAT Pune29 Oct 2025AY 2018-2019

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.755/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Indrajeet Suresh Magar, Ito, Ward-2(1), Kolhapur. 100, Saroj Niwas, Ruikar Vs. Colony, Kolhapur- 416003. Pan : Aiapm7745G अपीलाथ" / Appellant ""थ" / Respondent Assessee By : Shri Farrukh Mohammad Munir Mulla Department By : Shri Ramnath P. Murkunde Date Of Hearing : 30-09-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 26.07.2024 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”] Pertaining To Assessment Year (“Ay”) 2018-19. 2. There Is Delay Of 172 Days In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Application For Condonation That The Assessee Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After Hearing Both The Sides, We Condone The Delay Of 172 Days & Proceed To Adjudicate The Appeal. 3. The Assessee Has Raised The Following Grounds Of Appeal :- “1. Incorrect Assessment Year: The Sale Of The Property On 12.04.2018 Should Be Taxable In Ay 2019-20, But It Has Been Incorrectly Assessed In Ay 2018- 19 By The Assessing Officer. 2. Proportional Taxation: The Assessee'S Ownership Is Only 50% & Hence The Capital Gain Should Be Taxed Proportionately. The Assessing Officer Has Failed To Account For This.

For Appellant: Shri Farrukh MohammadFor Respondent: Shri Ramnath P. Murkunde
Section 147Section 148A

other charges paid for purchase deduction. Rs. 1,11,875/-. The indexed cost of purchase should be allowed as a deduction. The cost of improvement of the property in FY 2012-13 is Rs. 10, 06,823/-. The indexed cost of improvement should be allowed as a deduction. Total Deduction ... Registration Service Tax and VAT 1,11,875/- 2011-12 184 1,70,246/- and Other Cost of Improvement 10,06,823/- 2012-13 200 14,09,554/- Total 73,62,560/- 4. Incorrect Tax Calculation: The tax on long-term capital gain should be calculated as capital gain – ((maximum

Ram Khilari Meena, Dausa vs. ITO, Dausa

In the result, the appeal of the assessee is allowed

ITA 1292/JPR/2025[2019-20]Status: DisposedITAT Jaipur28 Oct 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Mukesh Khandelwal, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT
Section 139Section 147Section 148Section 148ASection 44A

that he has sold an immovable property for Rs. 21,00,000 and out of which credit was taken in respect of cost of improvement with indexation at Rs. 10,21,898 and offered Rs.72,114 as capital gains. The assessee was specifically asked to furnish the evidence

DCIT Circle 2.3.1, Mumbai vs. Prestige Holiday Resorts Private Limited, Mumbai

In the result, ground no. 2 and 3 are

ITA 4162/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Oct 2025AY 2016-17

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 2(11)Section 2(22)(e)Section 253(3)Section 254(1)

payment made to four group entities and capitalised the value at Rs.3.37 crores and the improvement towards land and Rs.18.91 crores as a cost of improvement towards building. Since the capitalisation was made at the end of the year, the assessee claimed depreciation on building @50% of 10% which ... assessee company. By making payments to group companies, the designated 252 units in the properties were made free from encumbrance and capitalised the cost of improvement of the property, ownership of which was already with the assessee, though it was not reflected in the balance-sheet. 11. The Ld.CIT

DCIT Circle 2.3.1, Mumbai vs. Prestige Holiday Resorts Private Limited, Mumbai

In the result, ground no. 2 and 3 are

ITA 4161/MUM/2025[2015-16]Status: DisposedITAT Mumbai28 Oct 2025AY 2015-16

Bench: Shri Pawan Singh& Shri Arun Khodpia

Section 2(11)Section 2(22)(e)Section 253(3)Section 254(1)

payment made to four group entities and capitalised the value at Rs.3.37 crores and the improvement towards land and Rs.18.91 crores as a cost of improvement towards building. Since the capitalisation was made at the end of the year, the assessee claimed depreciation on building @50% of 10% which ... assessee company. By making payments to group companies, the designated 252 units in the properties were made free from encumbrance and capitalised the cost of improvement of the property, ownership of which was already with the assessee, though it was not reflected in the balance-sheet. 11. The Ld.CIT

Maharashtra State Road Development Corporation Ltd, Mumbai vs. DCIT 5(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3484/MUM/2014[2006-07]Status: DisposedITAT Mumbai27 Oct 2025AY 2006-07

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Dalpat Shah, Shri. B S SharmaFor Respondent: Shri. Leyaqat Ali Aafaqui, Sr. AR
Section 143(3)Section 147Section 250

cash flow for a period of 15 years included in contract. 2. Rs. 402.93 cores is shown as advances towards the expected cost of improvement of Mumbai-pune section of NH-4 and Mumbai-Pune express way. This amount will be amortized over contract period along with the above ... gross amount as per Notes to Accounts is that the assessee has accounted advance toll receipt is Rs. 237.87 crores and the cost of improvement accounted as advances is Rs. 97.47 crores. On further appeal the Ld. CIT(A) confirmed the impugned additions made

Vishnukumar Cokalchand Gupta, Mumbai vs. ACIT Circle 19(3), Mumbai

In the result, the appeal is allowed for statistical purpose

ITA 4578/MUM/2025[2016-17]Status: DisposedITAT Mumbai23 Oct 2025AY 2016-17

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI NARENDRA KUMAR BILLAIYA (Accountant Member)

For Appellant: Shri Ajay R. Singh a/wFor Respondent: Ms. Kavita Kaushik

short), Delhi pertaining to the assessment year (A.Y.) 2016-17. 2. The solitary dispute in the appeal relates to disallowance of indexed cost of improvement while computing income under the head long term capital gain (‘LTCG’ for short). Briefly the facts are, the assessee is a resident individual ... year under dispute for a consideration of Rs.7,93,55,000/-. While computing LTCG, the assessee claimed deduction towards cost of acquisition and cost of improvement and offered net LTCG of Rs.5,77,55,811/-. Insofar as, cost of improvement is concerned, the assessee claimed an amount of Rs.36

Deputy Commissioner of Income Tax, Central Circle-1(2), Chennai vs. Mohamed Muyeenuddin Pazhoor Kochu Mohamed, Kanchipuram

In the result, the appeal filed by the Revenue is allowed for statistical purposes

ITA 923/CHNY/2025[2018-19]Status: DisposedITAT Chennai22 Oct 2025AY 2018-19

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.: 923/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 The Deputy Commissioner Of Shri Mohamed Muyeenuddin Income Tax, Vs. Pazhoor Kochu Mohamed, Central Circle 1(2), E1, 2Nd Main Road, Chennai. Juhu Beach, Sholinganallur S.O., Uthandi, Kanchipuram – 600 119. Pan: Aaipm 4366P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Shiva Srinivas, Cit ""यथ" क" ओर से/Respondent By : Shri Darshan Bothra, Ca सुनवाई क" तारीख/Date Of Hearing : 21.10.2025 घोषणा क" तारीख/Date Of Pronouncement : 22.10.2025

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri Darshan Bothra, CA
Section 132Section 139(1)Section 153CSection 194Section 250

paid a sum of Rs.3.10 crores to the other co-owners. Further, the Long-Term Capital Gains computation was varied by rejecting the cost of improvement claimed by the assessee and the construction cost of the residential building. :- 4 -: 4. Aggrieved by the assessment completed u/s.153C of the Act vide

Chickanna Govindappa, Bengaluru vs. Income Tax Officer, Ward-5(2)(1), Bengaluru

In the result, the appeal filed by the assessee is allowed

ITA 1663/BANG/2025[2016-17]Status: DisposedITAT Bangalore22 Oct 2025AY 2016-17

Bench: Shri Prashant Maharishiassessment Year : 2016-17

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for the Revenue
Section 133(6)Section 143(3)Section 69C

being the commission & brokerage paid by assessee for sale of property taxed u/s. 69C of the Act and further not allowing the cost of improvement of Rs.2,45,141 while computing the capital gain on the sale of property. 3. The brief facts of the case show that assessee ... Against the sale of property the assessee has claimed a sum of Rs.65.62 lakhs out of which Rs 2,45,141 as cost of improvement and further deduction of commission & brokerage paid of Rs.7,44,000 which was disallowed. 4. The ld. AO examined these two claims and found that

Assistant Commissioner of Income Tax, Circle-1(1), Tirupati vs. Venkata Swamy Ravuri, Chittoor

In the result, the appeal of the Revenue is allowed for

ITA 257/HYD/2022[2017-18]Status: DisposedITAT Hyderabad17 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdia

For Appellant: Advocate Sashank Dundu
Section 143(3)Section 2Section 68

instead of Rs.1,55,000/- claimed by the assessee. Further, since the assessee did not furnish any documentary evidence in support of cost of improvement, the Ld. AO disallowed the same and computed the long-term capital gain accordingly. On appeal, the Ld. CIT(A) accepted the assessee’s contention ... allowed both the full cost of acquisition at Rs.1,55,000/- and the cost of improvement of Rs.35,29,170/-, thereby deleting the addition. Aggrieved, the Revenue is in appeal before this Tribunal. 13. The Ld. DR invited our attention to para no.8 of the order

Sahil Kohli, New Delhi vs. DCIT Central Circle-16, New Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 453/DEL/2024[2019-20]Status: DisposedITAT Delhi17 Oct 2025AY 2019-20

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153ASection 250

gain on account of sale of property made by Ld. AO in absence of documentary evidence furnished by the appellant with respect to cost of improvement. 7) That in the facts and circumstances of the case and in law the Ld. CIT(Appeal) erred in upholding addition of Rs.1

Sahil Kohil, Delhi vs. DCIT, Central Circle-16, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 452/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Oct 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153ASection 250

gain on account of sale of property made by Ld. AO in absence of documentary evidence furnished by the appellant with respect to cost of improvement. 7) That in the facts and circumstances of the case and in law the Ld. CIT(Appeal) erred in upholding addition of Rs.1

Deputy Commissioner of Income Tax Central Circle - 16, Delhi vs. Sahil Kohli, Delhi

In the result, the cross objection filed by the assessee is allowed and appeal of the revenue is dismissed

ITA 3283/DEL/2023[2015-16]Status: DisposedITAT Delhi17 Oct 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Manish Agarwal

Section 143(2)Section 153ASection 250

gain on account of sale of property made by Ld. AO in absence of documentary evidence furnished by the appellant with respect to cost of improvement. 7) That in the facts and circumstances of the case and in law the Ld. CIT(Appeal) erred in upholding addition of Rs.1

Kiran Yadav, Jaipur vs. Income Tax Officer, Ward-1(3), Jaipur

In the result, the appeal of the assessee is partly allowed

ITA 853/JPR/2025[2017-18]Status: DisposedITAT Jaipur16 Oct 2025AY 2017-18

Bench: BEFORE: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri K.L. Moolchandani-ARFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

long term capital gain. The AO further held that the expenses incurred on security guard cannot be regarded as capital asset or cost of improvement to capital asset. 4.3.3 The appellant has not filed any details such as for the payment made, documentary evidence in this regard such as mode ... have been brought vide above reply. From the above details narrated in the order, it can be seen that the assessee enhanced the cost of improvement on mittibharai and boundary wall and added expenses on security guard in the revised computation when he was brought the provisions of section

Harshadkumar Hargovandas Patel, Kalol vs. The ITO, Ward-4, Mehsana

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

ITA 125/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2013-14

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Adv. & ShriFor Respondent: Shri Abhijit, Sr. D.R
Section 143Section 143(3)Section 148Section 55A

taking gross cost of purchase at Rs. 21,46,300/- instead of correct cost of purchase of Rs.23,08,800/- and rejecting gross cost of improvement and gross cost of transfer aggregating to Rs.7,75,000/-. 3. The ld. CIT(A) grossly erred in law and on facts in confirming ... dismissed the assessee's appeal. 3.2 Further, the Assessing Officer made a disallowance of Rs.13,00,000/- claimed by the assessee towards indexed cost of improvement and expenditure on transfer. The assessee had produced certain handwritten bills and notes to substantiate the claim. The Assessing Officer found that

Harshadkumar Hargovandas Patel, Kalol vs. The ITO, Ward-4, Mehsana

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

ITA 124/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2013-14

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Adv. & ShriFor Respondent: Shri Abhijit, Sr. D.R
Section 143Section 143(3)Section 148Section 55A

taking gross cost of purchase at Rs. 21,46,300/- instead of correct cost of purchase of Rs.23,08,800/- and rejecting gross cost of improvement and gross cost of transfer aggregating to Rs. 7,75,000/-. 3. The Id. CIT(A) grossly erred in law and on facts ... assessee’s appeal. 3.2 Further, the Assessing Officer made a disallowance of Rs. 13,00,000/- claimed by the assessee towards indexed cost of improvement and expenditure on transfer. The assessee had produced certain handwritten bills and notes to substantiate the claim. The Assessing Officer found that all the bills

Hamid Ali, Rohtas vs. ITO, Ward- 3 (4), Sasaram

In the result, ITA No.356/Pat/2025 is partly allowed for statistical purposes and ITA No

ITA 357/PAT/2025[2018-19]Status: DisposedITAT Patna10 Oct 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Rakesh Mishraita Nos.356 & 357/Pat/2025 Assessment Years: 2018-19 Hamid Ali…..……………..……………………….……….……….……Appellant C/O Gulam Murtaza Zakki Shaheed, Sasaram, Rohtas, Bihar – 821115. [Pan: Atppa8563N] Vs. Ito, Ward-3(4), Sasaram.…………………………….....……...…..…..Respondent Appearances By: Shri A.K. Rastogi, Sr. Adv. & Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 06, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Madhumita Roy: Both The Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 12.12.2024 Passed By Nfac, Delhi Arising Out Of The Orders Dated 23.02.2021 & 23.08.2021 Passed U/S 143(3) & U/S 270A Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Respectively For Assessment Year 2018-19. Ita No.356/Pat/2025 Relates To Quantum Order Whereas Ita No.357/Pat/2025 Relates To Penalty Order.

Section 143(3)Section 270ASection 50C(2)(a)Section 53C

taking stamp duty value as per his consideration for calculation of long- term capital gains, the assessee has not furnished any reply on cost of improvement and not assigned any reason for taking stamp value as his consideration for calculation of long-term capital gains. However, the purchase deed