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    <title>2025 (12) TMI 536 - ITAT BANGALORE</title>
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    <description>The Tribunal partly allowed the assessee&#039;s appeal. It held that, for computing capital gains on sale of flats under a JDA, the cost of land must be allocated only to the saleable/built-up area, enhancing the allowable cost per sq. ft. It applied s.50C third proviso and directed adoption of the actual sale consideration for a villa, as stamp value did not exceed 110% thereof. The assessee was granted full exemption under s.54, accepting unvouched expenditure of about 5% as incidental to construction. Notional rental income on two villas kept for sale during the Covid period was deleted under s.23(1)(c). However, capital gains on transfer of land under the JDA were confirmed as short-term capital gains.</description>
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      <link>https://www.taxtmi.com/caselaws?id=782996</link>
      <description>The Tribunal partly allowed the assessee&#039;s appeal. It held that, for computing capital gains on sale of flats under a JDA, the cost of land must be allocated only to the saleable/built-up area, enhancing the allowable cost per sq. ft. It applied s.50C third proviso and directed adoption of the actual sale consideration for a villa, as stamp value did not exceed 110% thereof. The assessee was granted full exemption under s.54, accepting unvouched expenditure of about 5% as incidental to construction. Notional rental income on two villas kept for sale during the Covid period was deleted under s.23(1)(c). However, capital gains on transfer of land under the JDA were confirmed as short-term capital gains.</description>
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      <pubDate>Fri, 28 Nov 2025 00:00:00 +0530</pubDate>
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