#Section 54 exemption

The ITAT Delhi has held that an Assessing Officer cannot substitute a registered valuer’s report with an arbitrary, unsupported methodology to compute indexed cost of acquisition under Section 48. This reinforces the legal primacy of expert valuation in capital gains assessments and protects taxpayers from speculative adjustments by revenue authorities.

The ITAT Bangalore has ruled that capital gains from the sale of multiple residential properties qualify for Section 54 exemption on a per-property basis, allowing taxpayers to reinvest gains from each sold flat into separate residential purchases without being capped at one house. This clarifies a long-standing ambiguity and benefits high-net-worth individuals and real estate investors who liquidate multiple units in a single financial year.

ITAT Ahmedabad rules that a mere agreement to purchase a residential property does not satisfy Section 54 exemption requirements; a registered conveyance deed is mandatory to claim capital gains tax relief. The ruling clarifies that taxpayers must ensure legal title transfer to avoid disallowance of exemptions, impacting property sellers relying on unregistered agreements.