Monday, July 8, 2013

Income from Capital Gains (Sec 45-55)

CAPITAL GAINS       (SEC. 45–55)
Sec. 45:       Charging Section
Any profits or gains arising from the transfer of a capital asset effected in the previous year, shall be deemed to the income of the previous year in which transfer took place.  The provisions are subject exemption u/s 54, 54B, 54D. 54EC, 54F, 54G and 54H of the Act.

Tansfer :     Defined u/s 2(47):  Transfer in relation to capital asset includes:

(i)                The sale, exchange, relinguishment of the asset; or
(ii)              The extinguishment of any right therein; or
(iii)            The compulsory acquisition thereof under any law, or
(iv)            Conversion  or treatment of capital asset into stock in trade; or
(iva) Maturity or redemption of a zero coupon bond; Zero coupon bond is defined  u/s 2(48); or
(v)              Transaction involving allowing retention/ possession of the immovable property u/s 53A of TPA Act, 1982 i.e (power of attorney)
(vi)            A transaction which has the effect of transferring or enabling the enjoyment of any immovable property by becoming member of a co-operative society, company, AOP/BOI to the member of the society, company, AOP/BOI.
Please note that the term transfer shall always include disposing of or parting with an asset and any interest therein.



Capital Asset:      Defined u/s 2(14)
Capital asset means property of any kind held by an assessee, whether or not connected with his business or profession, but does not include
(i)                            Any stock in trade, consumable store, raw material held for the purposes of business or profession

Personal effect i.e moveable property (including wearing apparel and furniture) helf for personal use by the assessee or any member of the family but excludes

(a)              Jewellery
(b)             Archaeological collections
(c)              Drawings
(d)             Paintings
(e)              Sculptures
(f)               Any work art
Explanation:-       For the purposes of this sub clause, jewellery includes:
(a)              Ornaments made of gold, silver, platinum or any other precious metal of any alloy of precious metal, stone, diamond whether or not worked in or sewn in wearing apparel;
(b)             Precious or semi precious stones whether or not set in or fixed in any furniture, utensils or other article or worked or sewn in wearing apparel.
(ii)                         Agricultural land in India –
(a)              other than land comprised within the jurisdiction of Municipality M.C, notified area committee, cantonment board which has population of not less than 10,000 according to the last census figures of which is published before the First day of previous year in the official gazette;  or
(b)             land not being within 8 K.M from local limits of Municipal limits – notified for urban development.
(iii)                       6 ½% Gold Bonds, 1977 or 7% Gold Bonds, 1980, National Defence Gold Bonds 1980 issued by Central Govt.
(iv)                       Special Bearer Bonds, 1991 issued by Cent. Govt.
(v)                         Gold Deposit bonds issued under Gold Deposit scheme, 1999, notified by Cent. Govt.
EXPLANATION:  It may please be noted that it is clarified that property includes and shall be deemed to have always included any rights in relation to any Indian company, including rights of management or control or any other rights whatsoever.


Capital assets – classified as
(i)                            Long term capital Asset      {sec. 2(29A)}
Means a capital asset which not a short-term capital asset
(ii)                         Short term capital Asset     {sec. 2(42A)}
Means a capital asset held by an assessee for not more than 36 months immediately preceding the date of its transfer

Capital Gains – classified as
(i)                            Long Term capital Gains    {sec. 2(29B)}
Means capital arising on transfer of long- term capital asset
(ii)                         Short Term Capital Gains  {sec. 2(42B)}
Means capital gain arising on transfer of a short-term capital asset
Provided:
          In the case of
(a) Shares of company,or
(b) security recognized in stock Exchange,or
(c) units of UTI or
(d) units of Mutual Funds (MF) or
(e) Zero Coupon Bonds:

Period of 36 months to be taken as 12 months

                  

MODE OF COMPUTATION OF CAPITAL GAIN
Section 48 prescribes method of computation:
How to compute short term capital gain:
Sale consideration:                                                         10,00,000
Less
(i)                            Cost of acquisition              6,00,000
(ii)                         Cost of improvement              80,000
(iii)                       Expenses incurred in
Connection with transfer       6,000       6,86,000
          Short term capital gain                               3,14,000


How to compute long term capital gain
Please ascertain the CII of purchase year and CII of year in which improvement is made


Mr. X purchased a house property on 10.07.2005 for Rs. 8,00,000/- He incurred expenditure on its improvement on 31.12.2008 at Rs. 1,00,000/-. He incurred expenditure of Rs. 20,000/- on payment of brokerage.  The property was sold on 7th of Aug. 2011 for Rs. 10,00,000/-   What is his long term capital gain?

Answer:
Name of the assessee:                                           Mr. X
Status:                                                                                     Individual
Previous year ended on                                        31.03.2012
Assessment Year:                                                 2012-13


Computation of L.T.C.G
Sale consideration (07.08.2011):               10,00,000
Less
(i): Indexed Cost of acquisition(ICA)
      COA  X CII of sale year
      CII of purchase year
          8,00,000 X785                             12,63,581
                   497
(ii): Indexed Cost of improvement(ICI)         
          COI  X CII of sale year
      CII of Improvement year
          1,00,000 X 785
                     582                                        1,34,879
(iii):Expenses in connection with
        transfer:                                                  20,000 14,18,460
          Long  term capital loss                                 (-)     4,18,460


Exemption  from  Capital  Gain
Sec. 54:                Purchase/construction   of new Residential house on sale of residential house. (house for house)
(a)              This section applies to individual, HUF only.
(b)              Long term capital gain arises on transfer of a residential house.
(c)              The long term capital gain is invested in the purchase of new residential house one(1) year before or two (2) years after the date of transfer of the original asset. or
(d)              The assessee constructs a new house within 3 years from the date of transfer of house.
Capital Gain Scheme 1988:
          Under this scheme, the assessee may deposit any amount in the scheme in any notified branch of the bank before the due date for filing the return of income u/s 139(1).  If the assessee deposits any amount under the scheme, before the due date of filing of return u/s 139 (1), the amount so deposited will be deemed to be the cost of new house for the purposes of exemption u/s 54 of the act.
   If the assessee does not purchase a new house property within two (2) years or constructs a new house within three years from the date of transfer of original house, the amount so deposited which is not utilized partly or wholly, will be included in his total income after the expiry of three (3) years, as the income of the assessee of the previous year in which the three years expires.
   The assessee is entitled to withdraw the amount deposited after the expiry of three (3) years .


 Exemption u/s 54B (Agricultural land for agricultural land.)
(a)              This section applies to individual only. W.e.f. A.Y. 2013-14, HUF has also been included.
(b)               Capital gain arises on transfer of agricultural   land, which was used for two (2) years before the date of transfer for agricultural purposes by him or  any parents.
(c)              The capital gain is invested in the purchase of another agricultural land within  two (2) years after the date of transfer of the original asset.

Capital Gain Scheme 1988:
          Under this scheme, the assessee may deposit any amount in the scheme in any notified branch of the bank before the due date for filing the return of income u/s 139(1).  If the assessee deposits any amount under the scheme, before the due date of filing of return u/s 139 (1), the amount so deposited will be deemed to be the cost of agricultural land for the purpose of exemption u/s 54B of the act.
   If the assessee does not purchase agricultural land within two (2) years from the date of transfer of original agricultural land, the amount so deposited, which is not utilized partly or wholly, will be included in his total income after the expiry of two (2) years, as the income of the assessee of the previous year in which the two (2) years expires.
   The assessee is entitled to withdraw the amount deposited after the expiry of two (2) years .

Exemption u/s 54EC . (Investment in specified bonds)
This section applies to any long term capital gain. Under this section the assessee may deposit any amount, out of long term capital gains, in  the purchase of notified bonds within six (6) months from the date of transfer, such as:
1.     Bonds of NHAI,
2.     Bonds of RECL.
In these bonds, lock in period is not less than 3 years.  After the expiry of three years, on maturity, the assessee gets back the amount deposited in the scheme.  The amount so received   is  not  taxable.   However the interest accrued  on these bonds is taxable on accrual basis year after year. 

He will be allowed exemption of the amount so deposited u/s 54EC. The maximum amount for deposit is Rs. 50,00,000.

The assessee should not take loan on these bonds. He should not transfer these bonds within three (3) years from the date of transfer.

 If the assessee violates, the exemption will be withdrawn in the year in which violation takes place.



Sec. 54F:   Purchase/construction of a residential house on transfer of any long term capital asset other than residential house.
(a)              This section applies to individual and HUF only.
(b)             The long term capital gain arises on transfer of any asset other than residential house.
(c)              The assessee purchases a new residential house one (1) year before of two (2) years after the date of transfer of asset or constructs a new residential house within three (3) years from the date of  transfer of any asset.
(d)             This section does not apply
(i)                            where the  assessee owns more than one residential house other new house
or
(ii)                         where assesssee purchases any residential house, other than new house, within one (1) year from  the date of transfer of original asset.
or
(iii)                       where assesssee constructs any residential house other than new house within three (3) year from  the date of transfer of original asset.
EXEMPTION:
(a)              if cost of new house is more than net  consideration, the whole of capital gain is exempt.
(b)             if cost of new house is less than net  consideration, proportionate capital is exempt.
Proportionate capital gain exempt:

LTCG X Cost of new house / net consideration

Meaning of net consideration:
Consideration received or accruing/receivable as reduced by expenses incurred in connection with the transfer of the asset.



Practical  problems

§  -3-                                                                                                                  MSE/2013
·        Q 5: Mr. Prasad sold a residential house in Delhi as per the following details:-
·        Date of transfer
·        January 15, 2012
·        Date of purchase
·        June 15, 2007
·        Sale consideration        
·        Rs. 85,00,000
·        Cost of acquisition
·        Rs. 28,00,000
·        Expenses on transfer
·        Rs.      55,000
·        Cost of renovation in F.Y. 2008-09
·        Rs.    2,00,000
o   He purchase a flat for residential purposes on 25.03.2012 at the cost of Rs. 25,50,000  compute the income under the head capital gains and tax payable for the A.Y. 2012-13.                                       MSE-2012

Income from capital gains
Long Term Capital Gains
Sale considerationL (15.01.2012)                                                   85,00,000
(a): Less Indexed Cost of Acquisition (15.06.2007)
28,00,000 X 785 /551:                                         39,89,111
(b): Indexed Cost of Improvement:  ( 2008-09)
2,00,000 X 785/582:                                              2,69,759
©:  Expenses on transfer:                                         55,000            43,13,869
Long term capital gain:                                                                            41,86,131
Less exemption u/s 54
Cost of new house of LTCG whichever is less:                               25,50,000
Taxable   long term capital gain:                                                    16,36,131
             
Rounded off u/s 288A:                                                  16,36,130  


                                      Computation of tax liability


Income-tax on Rs. 1,80,000:                                Nil
Income-tax on Rs. 14,56,130 @ 20%
u/s 112:                                                                2,91,226

Education Cess @ 3%                                               8,737
Total:                                                                             2,99,963

Rounded off u/s 288B:                                         2,99,960





·        Q 6        A piece of land owned by Mr. Kumar located in Patna purchased on 10.04.2007 for Rs. 27,00,000 was sold by him on 12.02.2012 for Rs. 41,00,000, but sale deed thereof could not be executed by 31.03.2012 though the possession of property was handed over of 08.03.2012. The Sale deed was finally registered on 14.04.2012. Mr. Kumar paid Rs. 50,000/- to the property broker for the above transaction on 08.03.2012. The value for the purpose of stamp duty applied by the Stamp Valuation Authority was Rs. 44,00,000/- which was not disputed by the buyer or seller and Stamp duty @ 8% was paid by the buyer of the property on the above amount.

(a)  Determine the assessment year in which the above transaction related to the Capital Gain should be taxed by the A.O.
(b) Compute the income chargeable to tax arising as a result of these transactions in the A.Y. 2012-13 and A.Y. 2013-14.                        MSE-(2012)

Name of the Assessee:                                         Mr. Kumar
Status:                                                                  Individual
Previous year ended on                                                31.03.2012
Assessment Year:                                                2012-13

                                      Computation of income
Income from  capital gains
Long Term Capital Gain
Deemed sale consideration u/s 50C              44,00,000
Less
          (a): Indexed cost of Acquisition
                   COA   X CII of sale year
                   CII  of  purchase year
                   27,00,000 X 785/551:   38,46,643
( b) Expenses in connection
       With transfer:                        50,000       38,96,643
Long Term Capital  Gain                                      5,03,357



Q. 7: Mr. Ashok Kumar, aged 70 years sold his only one residential house for Rs. 20,00,000 in April 2011. The house was purchased for Rs. 2,00,000 in May 1996. He has purchased a flat for his residential purpose in December 2011. For Rs. 10,00,000. Compute the income under the head Capital Gains and tax payable thereon for Assessment Year 2012-13                                                                                                                                                                   (MSE-2006)


Name of the Assessee:                                Mr. Ashok Kumar
Status:                                                        Individual (Sr. Citizen)
Previous year ended on                                       31.03.2012
Assessment Year:                                       2012-13

                                      Computation of income
Income from  capital gains
L.T.C.G on sale of house
Sale consideration:                                                       20,00,000
Less
(a):  ICOA
          2,00,000 785/305:                   5,14,754       5,14,754
LTCG:                                                                                    14,85,246

Less exemption u/s 54:
          Cost of new house of LTCG
          Whichever is less:                                                10,00,000
Taxable LTCG:                                                               4,85,246

Rounded off u/s 288A:                                       4,85,250

                             Computation of tax liability:

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