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Income From Capital Gains
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Chargeability u/s 45
Profits or gains arising from the transfer of a capital
asset is chargeable to tax in the year in which transfer take place under the
head "Capital Gains".
Definitions
Transfer: Sec. 2(47): Transfer in relation to a capital
asset includes sale, Exchange, or relinquishment of the asset or
extinguishment of any rights therein or the compulsory acquisition thereof
under any law or conversion of the asset by the owner in stock-in-trade of a
business carried on by him or the maturity or redemption of a zero coupon
bond.
Capital Asset: Sec. 2(14): Capital Asset means property
of any kind (Fixed, Circulating, movable, immovable, tangible or intangible)
whether or not connected with business or profession.
Exclusions —
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Stock-in-trade
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Personal
effects of the assessee
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Agricultural
land in a rural area
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6½% Gold Bonds,
1977 or 7% Gold Bonds, 1980 or National Defence Bonds, 1980 issued by the
Central Government
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Special Bearer
Bonds, 1991 issued by the Central Government.
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Gold Deposit
Bonds issued under Gold Deposit Scheme 1999
Short-term capital asset: Sec. 2(42A): means a capital
asset held by an assessee for not more than thirty six months immediately
preceding the date of its transfer. However, in the following cases, an asset,
held for not more than twelve months, is treated as short-term capital asset—
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Quoted or
unquoted equity or preference shares in a company
Circular No. 495 dated
22.9.1987 explaining amendments by Finance Act, 1987 whereby unquoted shares
of a private limited company also if held more than 12 months falls in the
category of LTCG. Also Refer the Judgment in 120 TTJ 699 for unquoted shares
held for less than 36 months.
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Quoted
Securities
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Quoted or
unquoted Units of UTI
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Quoted or
unquoted Units of Mutual Funds specified u/s. 10(23D)
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Quoted or
unquoted zero coupon bonds
Long-term capital asset: Sec. 2(29A): means a capital
asset which is not a short-term capital asset
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Year of chargeability to tax
Capital gains are generally charged to tax in the year in
which ‘transfer’ takes place. Exceptions —
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Sec. 45(1A) —
Insurance Claim — In the year of receipt.
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Sec. 45(2) —
Conversion of capital asset into stock-in-trade — In the year of actual sale
of the stock.
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Sec. 45(5) —
Compulsory acquisition — When consideration or part thereof is first
received.
Exempt Capital Gains under Section 10
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10(33) |
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Transfer of US 64 on or
after April 1, 2002 |
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10(37) |
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Compulsory acquisition
of Urban Agriculture Land where consideration is received after March 31,
2004. |
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10(38) |
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Long-term capital gain arising on
transfer on or after October 1, 2004 of equity shares or units of equity
oriented mutual fund and the STT is paid at the time of transfer. |
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Computation of capital gains (Sec. 48)
The method of computation depends on the nature of capital
asset transferred. It is as follows:—
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Short-term
Capital Gain |
Long-term Capital Gain |
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A. Find out Full Value of
Consideration |
A. Find out Full Value of Consideration |
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B. Deduct: |
B. Deduct: |
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(i) expenditure incurred wholly and
exclusively
in connection with such Transfer.
(ii) Cost of Acquisition
(iii) Cost of Improvement
(iv) Exemption provided by Ss. 54B,
54D & 54G, 54GA |
(i) expenditure incurred wholly and
exclusively in connection with
such Transfer.
(ii) Indexed Cost of Acquisition
(iii) Indexed Cost of Improvement
(iv) Exemption provided by Ss. 54,
54B, 54D, 54EC, 54ED, 54F & 54G, 54GA |
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C. (A-B) is short-term capital gain |
C. (A-B) is a long-term capital gain |
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Full value of consideration for transfer of land or
building or both: Sec. 50C
Higher of the followings:—
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Full value of
the consideration received or accruing
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Value adopted
or assessed (w.e.f. 1st day of October, 2009 the word "or assessed" shall be
substituted by "or assessed or assessable") by any authority of a State
Government for the purpose of payment of stamp duty in respect of such
transfer.
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Indexed Cost of acquisition = Cost of acquisition * Cost
inflation index for the financial year In which the asset is transferred/ Cost
inflation index for the first financial year in which the asset was held by
the assessee or the year beginning on 1.4.1981, whichever is later or the year
of Improvement of the asset
However, in case of Bonds, Debentures except capital
indexed bonds depreciable assets, and for non-residents even if they are long
term capital assets the benefit of indexation is not available.
Cost inflation Index
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Financial Year |
Cost Inflation
Index |
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1981-82 |
100 |
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1982-83 |
109 |
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1983-84 |
116 |
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1984-85 |
125 |
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1985-86 |
133 |
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1986-87 |
140 |
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1987-88 |
150 |
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1988-89 |
161 |
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1989-90 |
172 |
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1990-91 |
182 |
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1991-92 |
199 |
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1992-93 |
223 |
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1993-94 |
244 |
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1994-95 |
259 |
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1995-96 |
281 |
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1996-97 |
305 |
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1997-98 |
331 |
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1998-99 |
351 |
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1999-2000 |
389 |
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2000-01 |
406 |
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2001-02 |
426 |
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2002-03 |
447 |
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2003-04 |
463 |
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2004-05 |
480 |
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2005-06 |
497 |
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2006-07 |
519 |
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2007-08 |
551 |
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2008-09
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582 |
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2009-10 |
632 |
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2010-11 |
711 |
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2011-12
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785 |
Computation of Long Term Capital Gains on Shares both
Equity and Preference, Listed or Unlisted and Debentures:
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Capital Assets
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If transaction is
covered by STT at the time of transfer
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IF
it is not covered by STT
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Long Term |
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Without
indexation |
With indexation |
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Listed equity shares covered by Sec. 10(36)
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0% |
0% |
0% |
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Listed equity shares not covered by Sec. 10(36)
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0% |
10% |
20% |
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Unlisted equity shares |
NA |
NA |
20% |
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Listed Preference shares |
NA |
10% |
20% |
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Unlisted Preference
shares |
NA |
NA |
20% |
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Listed Debenture |
NA |
10% |
NA |
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Unlisted Debenture |
NA |
20% |
NA |
CAPITAL GAIN IN CASE OF CONVERSION OF A PRIVATE COMPANY OR
AN UNLISTED PUBLIC COMPANY INTO AN LLP:
Sec. 47(XIIIb)
This section provides that conversion of a private company
or unlisted public company into an LLP in accordance with Secs. 56 and 57 of
the LLP Act will not be regarded as transfer, if following conditions are
fulfilled :
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All the assets
and liabilities of the company become the assets and liabilities of the LLP.
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All the
shareholders of the company become the partners of the LLP and their profit
sharing ratio and the capital contribution in the LLP are in the same
proportion as their shareholding in the company on the date of conversion.
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Shareholders of
the company do not receive any consideration or the benefit, directly or
indirectly, other than share in the profit and capital contribution in the
LLP.
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For a period of
at least five years from the date of conversion, the erstwhile shareholders
of the company in aggregate are entitled to at least 50% of the profits of
the LLP.
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The total
sales, turnover or gross receipts in the business of the company in any of
the three years preceding the year of conversion do not exceed Rs. 60 lakhs.
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For a period of
three years from the date of conversion, the accumulated profits of the
company on the date of conversion are not paid to any partner of the LLP,
whether directly or indirectly.
Sec. 47A (4)
This section provides that if any of the conditions in (a)
to (f) above are not complied with, then the profits arising from transfer of
capital assets or intangible assets on conversion of the company to the LLP
not charged under Sec. 45 shall be taxed in the hands of the LLP in the year
in which the conditions are violated.
Sec. 49
It provides that cost of acquisition of the capital assets
acquired by the LLP in the process of conversion shall be deemed to be the
cost for which the converted company had acquired the assets.
CAPITAL GAINS - VARIOUS EXEMPTIONS DETAILS
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Section |
54 |
54B |
54D |
54EC
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(a) |
Kind of assets transferred |
Long-term Capital
Assets being House
Property used for
residential purpose |
Land used for
agricultural purposes |
Land and Building or
any right therein used
by an industrial
undertaking
compulsorily acquired
under any law |
Any Long Term Capital
Assets |
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(b) |
Eligible Assessees |
Individual & HUF |
Individual & HUF |
All |
All |
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(c) |
Condition of
period of
holding of
original Asset |
3 years |
2 years |
2 years |
1 year for Shares, Listed
Securities, Units of UTI/
Mutual Fund specified
u/s 10(23D), Zero
coupon bonds, 3 years
for any other capital
assets |
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(d) |
Condition of
utilization of
consideration |
Purchase of
Residential House
within 2 years after
or 1 year prior to
date of transfer: or
construction of
residential house
within 3 years from
the date of transfer |
Purchase of
Agricultural Land
within 2 years from
the date of transfer |
Purchase/construction
of land, building, or
any right therein
within 3 years from the
date of transfer by
way of compulsory
acquisition for the
purpose of shifting/
re-establishing/
setting up another
industrial undertaking |
Investment of whole or
any Part of Capital Gain
in ‘specified assets’ as
stipulated in the section.
Investment should be
made within 6 months
from the date of transfer |
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(e) |
Exempt
Amount |
The amount of gain
or, the cost of new
asset, whichever is
less |
Lower of the Capital
Gain or the Cost of
acquisition of new
agricultural land |
Lower of the Capital
Gain or the Cost of
acquisition of new
land and building |
Lower of the Capital
Gain or the investment
in specified assets subject to a maximum of Rs. 50 lakhs. |
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(f) |
Other requirements |
See notes 1, 2 & 4 |
Assessee or his
parents must have
used the land for
agricultural purpose
for preceding two
years |
See notes 1, 2 & 4
Must have been
used for business of
industrial undertaking
for preceding 2 years |
See notes 1, 2 & 4
Rebate u/s 88 or
deduction u/s 80C not to be granted for the same investment. New Asset
must be retained for a
period of 3 years |
CAPITAL GAINS - VARIOUS EXEMPTIONS DETAILS
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Section |
54F |
54G |
54GA |
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(a) |
Kind of asset transferred |
Any long term capital asset other than
residential house |
Land or Building or any right therein or
Plant or Machinery in Urban Area used for the business |
Land or Building or any right therein or
Plant or Machinery in Urban Area used for the business |
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(b) |
Eligible Assessees |
Individual & HUF |
Industrial undertakings in urban area
shifting to an area other than urban area |
Industrial undertakings in urban area
shifting to any Special Economic Zone |
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(c) |
Condition of period of holding of
original asset |
1 year for Shares, Listed
Securities, Units of UTI/
Mutual Fund specified
u/s 10(23D), Zero-coupon
bonds, 3 years for other
capital assets |
No period specified
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No period specified
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(d) |
Condition of utilization of
consideration |
Purchase of Residential House within 2
years after or 1 year prior to date of transfer; or construction of
residential house within 3 years from date of transfer |
Acquire similar assets & incur expenses
on shifting original asset, within 1 year before, or 3 years from the date
of transfer |
Acquire similar assets & incur expenses
on shifting original asset, within 1 year before, or 3 years from the date
of transfer |
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(e) |
Exempt Amount |
Refer Note No. 5 |
The amount of gain or the aggregate cost
of new asset, and shifting expenses, whichever is lower |
The amount of gain or the aggregate cost
of new asset, and shifting expenses, whichever is lower |
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(f) |
Other Requirements |
Must not own more than 1 residential
house other than the new asset on the date of transfer of original asset |
Must have been shifted to non-urban
area. See Notes 1 & 2 |
See Notes 1, 2, 3 and 4 |
NOTES
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In case New
Asset is transferred before 3 years from date of purchase/construction, the
Capital Gains exempted earlier will be chargeable to tax in year of transfer
of new asset.
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In order to
avail the exemption, gains are to be reinvested, before the due date of
return u/s 139(1). If the amount is not so reinvested, it is to be deposited
on or before that date in account of specified bank/institution and it
should be utilised within specified time limit for purchase/construction of
new asset.
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U/s 54F Capital
Gains exempted earlier shall be chargeable to tax — if a) If the assessee
purchases within 2 years or constructs within 3 years any residential house
other than the one in which reinvestment is made & b) If the new asset is
transferred within a period of 3 years from the date of its
purchase/construction.
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As per Section
54H, where the transfer is by way of compulsory acquisition, the period
available for acquiring the new asset u/ss. 54, 54B, 54D, 54EC and 54F shall
be computed from the date of receipt of compensation and not the date of
transfer.
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If cost of new
house is more than the net consideration of original asset, the whole of the
gains is exempt. If cost of specified asset is less than net consideration,
proportionate amount of the gains will be exempt i.e. Capital Gain X cost of
New Asset/Net consideration on sale of asset.
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