https://www.taxtmi.com/caselaws?id=27892 Tenancy rights are capital assets, and their surrender ordinarily amounts to a transfer because extinguishment of rights is included within the definition of transfer. However, capital gains under section 45 can arise only where the cost of acquisition can be ascertained and the computation mechanism under section 48 can operate as an integrated code. Where tenancy rights were self-generated and acquired without cost, the computation provisions fail and the receipt falls outside capital gains taxation. The option under section 55(2)(i) to adopt fair market value was treated as inapplicable because computation was otherwise impossible. en-us Fri, 06 Jan 1984 00:00:00 +0530 Thu, 30 Oct 2025 21:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27892 Tenancy rights are capital assets, and their surrender ordinarily amounts to a transfer because extinguishment of rights is included within the definition of transfer. However, capital gains under section 45 can arise only where the cost of acquisition can be ascertained and the computation mechanism under section 48 can operate as an integrated code. Where tenancy rights were self-generated and acquired without cost, the computation provisions fail and the receipt falls outside capital gains taxation. The option under section 55(2)(i) to adopt fair market value was treated as inapplicable because computation was otherwise impossible. Case-Laws Income Tax Fri, 06 Jan 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27892