CBDT FAQ Deep-Dive Series #4: Capital Gains Transition Under Section 536 Sub-Clause 5 of the Income-tax Act 2025 – Sections 45 to 55A of the 1961 Act, Section 47 Exempt Transfers, Section 48 Indexation, Section 49 Cost of Acquisition, Section 54 to 54GB Reinvestment Exemptions, and the Pre-April 2026 / Post-April 2026 Asset Holding Period Cutover for FY 2025-26 Files
Key Takeaways
- Section 536 sub-clause 5 of the Income-tax Act 2025 preserves the entire Sections 45 to 55A capital-gains framework of the 1961 Act for assets transferred during FY 2025-26 (AY 2026-27) and earlier previous years, irrespective of when the consideration is received.
- Holding-period clock keeps running across the April 1, 2026 cutover. An asset acquired in May 2018 and transferred in October 2026 still uses the original cost, the original holding-period start date, and the 1961 Act framework for any deemed transfer event that crystallised on or before March 31, 2026.
- Finance Act 2024 unified LTCG rate of 12.5 per cent (Section 112) and the rationalised holding periods (12 months listed securities, 24 months other assets) are the operative rates for any AY 2026-27 transfer. The pre-July 23, 2024 grandfathering window for unlisted assets is closed; only land and building have the optional 12.5 per cent without indexation versus 20 per cent with indexation choice on pre-July 23, 2024 acquisitions.
- Section 47 exempt-transfer events (gift, will, partition, amalgamation, demerger, slump sale, LLP conversion under clause xiiib, business reorganisation under clause xiiia) that take place on or before March 31, 2026 anchor the donee or successor cost under Section 49 with the donor or predecessor cost and holding-period date carried forward.
- Section 54, 54B, 54D, 54EC, 54F, 54G, 54GA, 54GB reinvestment exemptions claimed in AY 2026-27 returns must be locked-in for the 3-year (54), 1-year prior / 2-year post (54), 5-year (54EC), 1-year prior / 3-year post (54F), or 5-year lock-in periods using the 1961 Act conditions. Successor Income-tax Act 2025 sections take over for AY 2027-28 transfers.
- Form ITR-2 / ITR-3 Schedule CG for AY 2026-27 continues to use the 1961 Act capital-gains rubric. Practitioners should map every client transfer transaction to a 1961 Act section before signing the return.
What Section 536 Sub-Clause 5 of the Income-tax Act 2025 Says About Capital Gains
The Income-tax Act 2025, gazetted on August 21, 2025 and effective April 1, 2026, replaces the Income-tax Act 1961 for income relating to assessment year 2027-28 and onwards. Section 536 of the new Act is the saving clause that preserves the 1961 Act framework for transitional events. Sub-clause 5 specifically deals with continuity of losses, deductions, exemptions, and credits already determined under the 1961 Act framework, and the larger transitional architecture (sub-clauses 1, 2, and 4 of Section 536) preserves the 1961 Act for any income, including capital gains, computed for any previous year ending on or before March 31, 2026.
For capital gains, this means that any asset transferred on or before March 31, 2026 attracts the 1961 Act framework, whether the consideration is received in cash, kind, or instalments straddling the cutover. The CBDT 99-page FAQ released earlier this quarter (see our Post 723 master FAQ deep-dive) confirms this position in the capital-gains chapter and treats the transfer date under Section 45(1) of the 1961 Act as the trigger event.
Capital Gains Charging and Computation Sections Preserved for AY 2026-27
The full Sections 45 to 55A capital-gains framework of the 1961 Act applies to AY 2026-27 transfers. The table below tabulates every operative provision practitioners need to lock into the FY 2025-26 file under Section 536.
| Section | Function | 1961 Act Position Preserved for AY 2026-27 |
|---|---|---|
| 45(1) | Charging section | Gains arising from transfer of a capital asset taxed in the previous year of transfer |
| 45(1A) | Insurance compensation | Taxed in year of receipt when asset destroyed by specified events |
| 45(2) | Conversion of capital asset to stock-in-trade | Taxed in year of sale of stock; FMV on conversion date is full value of consideration |
| 45(3) | Capital contribution to firm or AOP | FMV recorded by firm is full value of consideration |
| 45(4) | Distribution on dissolution / partner reconstitution | FMV of money plus capital asset received treated as full value of consideration |
| 45(5A) | JDA (Joint Development Agreement) for individuals/HUF | Taxed in year of completion certificate issuance |
| 46 | Distribution of assets by company on liquidation | FMV less deemed dividend under Section 2(22)(c) is full value of consideration |
| 47 | Transactions not regarded as transfer (gift, will, partition, amalgamation, demerger, LLP conversion, business reorganisation) | Full 25-clause exempt-transfer catalogue preserved for events on or before March 31, 2026 |
| 48 | Mode of computation, indexation, foreign-currency conversion for non-resident, transfer expenses | Cost of acquisition and cost of improvement, indexed where the asset qualifies (land and building only post FA 2024), reduced from full value of consideration |
| 49 | Cost of acquisition with reference to certain modes | Donor / predecessor / amalgamating company / partition family member cost carried forward; holding period also carried forward |
| 50 | Special provision for depreciable assets (block of assets) | Short-term capital gain / loss computed as WDV of block plus actual cost of new addition less full value of consideration; balance carried in block |
| 50A | Special provision for power undertakings | Section 41 plus capital gains hybrid |
| 50B | Slump sale | Net worth deemed cost; STCG if undertaking held less than 36 months; LTCG otherwise |
| 50C | Deemed full value for land/building | Stamp duty value if higher than declared consideration, subject to 10 per cent tolerance band |
| 50CA | Deemed full value for unquoted shares | FMV per Rule 11UAA if higher than declared consideration |
| 50D | FMV deemed as consideration when actual consideration not ascertainable | FMV on date of transfer |
| 51 | Advance forfeited | Deducted from cost of acquisition for transfers on or after April 1, 2014 |
| 54 to 54GB | Reinvestment exemptions | Residential house (54), agricultural land (54B), industrial undertaking (54D), specified bonds (54EC), proceeds in residential house (54F), industrial undertaking from urban area (54G/54GA), eligible start-up shares (54GB) |
| 55 | Cost of acquisition for special assets | FMV on April 1, 2001 option for assets acquired before April 1, 2001; Nil cost for self-generated goodwill, tenancy, trademark, route permit, loom hours, etc. |
| 55A | Reference to Valuation Officer | AO may refer FMV question to DVO; binding subject to objection process |
Holding Period and Tax Rate Grid for AY 2026-27 Transfers
Finance Act 2024 rationalised holding periods to two buckets only and unified the LTCG rate. The Section 2(42A) holding-period grid and Section 111A / 112 / 112A rate grid that apply to AY 2026-27 transfers are:
| Asset Class | Holding Period for LTCG | Section | STCG Rate | LTCG Rate (Sec 112 / 112A) |
|---|---|---|---|---|
| Listed equity shares, equity-oriented mutual fund units, units of business trust (STT-paid) | more than 12 months | 2(42A) + 112A | 20 per cent (Section 111A, raised from 15 per cent by FA 2024 wef July 23, 2024) | 12.5 per cent above Rs 1.25 lakh exemption (Section 112A, raised from Rs 1 lakh by FA 2024) |
| Listed bonds, debentures, listed REIT / InvIT units (no STT) | more than 12 months | 2(42A) + 112 | Slab rate | 12.5 per cent without indexation |
| Unlisted shares, immovable property, gold, jewellery, paintings, other capital assets | more than 24 months | 2(42A) + 112 | Slab rate | 12.5 per cent without indexation (for transfers on or after July 23, 2024) |
| Immovable property (land or building) acquired before July 23, 2024 | more than 24 months | 2(42A) + 112(1) proviso | Slab rate | Lower of 12.5 per cent without indexation OR 20 per cent with indexation (resident individuals and HUFs only) |
| Debt mutual funds and market-linked debentures acquired on or after April 1, 2023 | Always STCG (Section 50AA) | 50AA | Slab rate (deemed STCG) | Not applicable |
| Debt mutual funds acquired before April 1, 2023 | more than 24 months | 2(42A) + 112 | Slab rate | 12.5 per cent without indexation (for transfers on or after July 23, 2024) |
Indexation note: Cost inflation indexation under Section 48 second proviso is preserved only for land and building acquired before July 23, 2024 in the hands of resident individuals and HUFs, who may elect the lower of 12.5 per cent without indexation or 20 per cent with indexation. For every other asset class, the cost inflation index has no application on transfers on or after July 23, 2024. The CII for FY 2025-26 (363) and prior years remains relevant only for this narrow election and for any deferred-consideration transactions where the transfer event occurred before July 23, 2024.
Section 47 Exempt-Transfer Continuity Across the April 1, 2026 Cutover
Section 47 lists 25 transactions that are not regarded as transfer. Section 49 then anchors the donee or successor cost to the donor or predecessor cost. Continuity of these provisions across the cutover is the single biggest concern for family-office and corporate restructuring practitioners. The Section 536 saving clause preserves the 1961 Act framework so that:
| Section 47 Clause | Transaction | Cost / Holding Period Anchor (Section 49) |
|---|---|---|
| 47(i) | Distribution on total partition of HUF | Section 49(1)(i) – cost in hands of HUF carried forward |
| 47(iii) | Transfer by gift, will, irrevocable trust | Section 49(1)(ii) – cost in hands of donor carried forward; donor’s holding period included (Explanation 1(i)(b) to Section 2(42A)) |
| 47(iv) / 47(v) | Holding company to wholly-owned Indian subsidiary or vice versa | Section 49(1)(iii)(e) – cost in hands of transferor carried forward; lock-in under Section 47A for 8 years |
| 47(vi) / 47(vib) / 47(vid) | Amalgamation, demerger, business reorganisation | Section 49(1)(iii)(e) and Section 49(2C)/(2D) – cost in hands of amalgamating or demerged company carried forward |
| 47(vii) / 47(viia) | Shares of amalgamated company received in exchange of amalgamating company shares | Section 49(2) – cost of amalgamating company shares carried forward to amalgamated company shares |
| 47(xiiib) | Conversion of unlisted private limited company to LLP | Section 49(1)(iii)(f) – cost in hands of converting company carried forward; 5-year lock-in under proviso to Section 47(xiiib) on partner profit share, asset distribution, and turnover threshold |
| 47(xiv) / 47(xvi) | Conversion of sole proprietorship / firm to company | Section 49(1)(iii)(e) – cost in hands of sole proprietor / firm carried forward; conditions of Sections 47(xiv) and 47(xvi) must be satisfied through the lock-in window |
| 47(viiae) | Strategic Investment Fund (Category I AIF) restructuring | Section 49(1)(iii)(e) – cost in hands of transferor preserved |
Practitioners must lock the supporting documentation (gift deed, will probate, scheme of amalgamation sanctioned by NCLT, demerger order, LLP conversion certificate from MCA, partition deed registered with the sub-registrar) into the FY 2025-26 file before March 31, 2026. If the transaction documentation is incomplete on the cutover date, the donee or successor cost may not anchor cleanly to the donor or predecessor cost when the asset is eventually transferred under the Income-tax Act 2025 framework.
Section 49 Cost of Acquisition – Six Operational Scenarios for Practitioners
Six common scenarios show how Section 49 cost continuity operates across the cutover:
- HUF partition in March 2026, member sells inherited property in July 2026. Section 49(1)(i) anchors the member’s cost to the HUF cost. The holding period includes the HUF holding period (Explanation 1(i)(b) to Section 2(42A)). LTCG under Section 112, computed at 12.5 per cent without indexation (transfer is post July 23, 2024); but member may elect 20 per cent with indexation if property was acquired by HUF before July 23, 2024.
- Gift of unlisted shares from father to son in February 2026, son transfers in November 2026. Section 49(1)(ii) anchors son’s cost to father’s cost. Father’s holding period included. If father held more than 24 months, son’s transfer is LTCG at 12.5 per cent under Section 112. Section 56(2)(x) does NOT apply on gift between specified relatives.
- NCLT-sanctioned amalgamation effective March 31, 2026; amalgamated company sells acquired plant and machinery in August 2026. Section 49(1)(iii)(e) anchors cost to WDV in books of amalgamating company. Block of asset continuity under Section 50 + Section 32 Explanation 7. STCG / LTCG computed at amalgamated company level.
- Sole proprietorship converts to private limited company on March 28, 2026 under Section 47(xiv); company transfers a portion of the inherited goodwill in October 2026. Section 49(1)(iii)(e) anchors company’s cost to proprietor’s cost. Goodwill cost under Section 55(2)(a) post Finance Act 2021 amendment is Nil for self-generated, FMV on date of acquisition for purchased; depreciation claimed by company since the date of acquisition reduces the cost. Section 47(xiv) lock-in conditions must continue to be satisfied through the post-cutover window.
- LLP converts to private limited company on March 25, 2026; company transfers acquired real estate in December 2026. Note: Section 47 does NOT exempt LLP-to-company conversion (only company-to-LLP is exempt under clause xiiib). The asset transfer in March 2026 itself triggers Section 45 read with Section 50C; the cost in the company’s hands is the FMV on date of conversion, not the LLP cost.
- Conversion of unlisted private limited to LLP on March 20, 2026 under Section 47(xiiib); LLP transfers acquired immovable property in September 2026. Section 49(1)(iii)(f) anchors LLP’s cost to the company’s cost. Holding period includes the company’s holding period. Five-year lock-in under proviso to Section 47(xiiib) on (a) the partners’ profit-sharing ratio (no partner gets less than 50 per cent of the original profit share for 5 years), (b) erstwhile shareholders’ minimum aggregate profit share of 50 per cent for 5 years, (c) no payment of any consideration other than profit share, and (d) the company’s turnover threshold of Rs 5 crore. Breach reactivates the deemed transfer under Section 47A(4).
Section 54 to 54GB Reinvestment Exemptions Locked in AY 2026-27 Returns
Reinvestment exemptions claimed in the AY 2026-27 return follow the 1961 Act conditions throughout the lock-in period, even if the lock-in extends beyond April 1, 2026.
| Section | Eligible Asset Sold | Eligible Reinvestment | Time Window | Capped Amount | Lock-in |
|---|---|---|---|---|---|
| 54 | Residential house (long-term) | One residential house in India (two houses if LTCG less than Rs 2 crore, one-time election) | 1 year before / 2 years after purchase; 3 years construction | Capped at Rs 10 crore exemption per Finance Act 2023 | 3 years – transfer of new house revokes proportionate exemption |
| 54B | Agricultural land (used for 2 years prior) | Agricultural land | 2 years after | No cap | 3 years – transfer of new land revokes |
| 54D | Industrial undertaking land/building compulsorily acquired | Industrial undertaking land/building | 3 years after | No cap | 3 years – revocation on transfer |
| 54EC | Long-term land or building | NHAI / REC / PFC / IRFC bonds (specified) | 6 months after | Rs 50 lakh per assessee per FY (also Rs 50 lakh in the next FY but counted for the same set of bonds) | 5-year lock-in on bonds; transfer / pledge breaks the exemption |
| 54F | Any long-term asset other than residential house | One residential house in India | 1 year before / 2 years after purchase; 3 years construction | Capped at Rs 10 crore exemption per Finance Act 2023 | 3 years – transfer of new house revokes; assessee should not own more than one other residential house on date of original transfer |
| 54G | Industrial undertaking shifted from urban area | Land, building, plant, machinery in non-urban area | 1 year before / 3 years after | No cap | 3 years – revocation on transfer |
| 54GA | Industrial undertaking shifted from urban area to SEZ | Land, building, plant, machinery in SEZ | 1 year before / 3 years after | No cap | 3 years – revocation on transfer |
| 54GB | Residential property (individual / HUF) by March 31, 2025 | Equity shares of eligible start-up (or MSME company); company further deploys in plant and machinery | Subscription by due date of ITR; deployment by company within 1 year | No cap | 5-year lock-in on shares (3 years for computers and software); breach revokes exemption |
Capital Gains Account Scheme (CGAS) deposit: Unutilised reinvestment amounts must be deposited in CGAS in a designated bank before the due date for filing the return (Section 139(1) for AY 2026-27 is July 31, 2026 for non-audit individuals and October 31, 2026 for audit cases). Failure to deposit forfeits the exemption.
Three High-Stakes Practitioner Scenarios Across the April 1, 2026 Cutover
Scenario 1: HNI with Listed-Equity Portfolio Switch in Late March 2026
Client sells listed equity shares on March 28, 2026 (settlement March 31, 2026). LTCG of Rs 8 lakh after Rs 1.25 lakh Section 112A exemption. STCG of Rs 4 lakh on shares held less than 12 months. Both are taxed under the 1961 Act for AY 2026-27. LTCG rate 12.5 per cent (Section 112A). STCG rate 20 per cent (Section 111A as amended by Finance Act 2024 wef July 23, 2024). Total tax Rs 1,00,000 (LTCG) plus Rs 80,000 (STCG) plus surcharge and cess. If client re-buys identical shares on April 2, 2026, the new acquisition is a fresh asset with cost equal to purchase price on April 2, 2026 and holding period begins April 2, 2026 (no wash-sale rule under Indian law). The buy-and-sell pair before March 31, 2026 captures the Rs 1.25 lakh annual exemption under Section 112A.
Scenario 2: Family Office Demerger Effective March 30, 2026; Subsidiary Sale in October 2026
NCLT sanctions demerger of an unlisted family-office holding company on March 30, 2026 under Section 47(vib). Demerged company’s identifiable undertaking transfers to resulting company. Shares of resulting company are issued to the holding company’s shareholders in proportion. Section 47(vii) and Section 49(2C) anchor the resulting company shares’ cost to the proportionate cost of the holding company shares. In October 2026 the family office sells the resulting company shares to a third-party buyer. Holding period under Explanation 1(i)(g) to Section 2(42A) includes the holding period of the original holding company shares, so the transfer is LTCG (24-month bar comfortably crossed). LTCG taxed at 12.5 per cent without indexation under Section 112 (unlisted shares, transfer post July 23, 2024). The demerger documentation (NCLT order, accountants’ certificate, scheme of arrangement) must be in the FY 2025-26 file by March 31, 2026 for Section 49(2C) cost continuity to apply.
Scenario 3: Founder Section 54F Re-Investment from Pre-IPO Share Sale in February 2026
Founder sells pre-IPO equity for Rs 3 crore on February 15, 2026. LTCG Rs 2.5 crore. Founder commits to buy a residential house worth Rs 4 crore by January 2028 (within 2 years post). Section 54F exemption applies on the proportionate amount of net consideration reinvested. Founder owns one other residential house (under the 54F limit of not more than one residential house other than the new house). The Rs 10 crore exemption cap of Section 54F per Finance Act 2023 leaves comfortable headroom. Until purchase or construction is complete, founder deposits the unutilised consideration in the CGAS by the AY 2026-27 ITR due date (July 31, 2026). The 3-year lock-in on the new house runs from purchase date; transfer within 3 years revokes the exemption proportionately. All conditions are evaluated under the 1961 Act framework even though the lock-in window extends to 2029.
Eight-Step Practitioner Capital-Gains File Review Sprint for FY 2025-26
- Map every client transfer transaction to a 1961 Act section: Section 45 charging event, Section 47 exempt-transfer, Section 50 depreciable, Section 50B slump sale, Section 50C/50CA/50D deeming.
- Confirm the transfer date falls on or before March 31, 2026. For JDA transactions, the completion certificate issuance date under Section 45(5A) controls; check whether the date is pre or post the cutover.
- Anchor Section 49 cost for inherited, gifted, partitioned, or reorganisation-received assets. Tag the donor/predecessor cost, FY of acquisition, and indexation basis if applicable.
- Compute LTCG/STCG holding period with the rationalised 12 or 24-month threshold. For Section 49 carried-forward assets, include the donor / predecessor / amalgamating company holding period.
- Apply the correct tax rate: 12.5 per cent (Section 112A above Rs 1.25 lakh for STT-paid listed equity), 12.5 per cent (Section 112 without indexation for other LTCG), 20 per cent (Section 111A for STT-paid listed STCG), slab rate (other STCG). For pre-July 23, 2024 land/building, evaluate the optional 20 per cent with indexation election for resident individuals and HUFs.
- Run Section 50C / 50CA stamp-duty / FMV comparison. If the deeming kicks in, document the 10 per cent tolerance band exhaustion and consider Section 55A reference to the DVO.
- Lock the Section 54 to 54GB reinvestment file: investment proof, CGAS deposit by ITR due date, 3-year / 5-year lock-in calendar, Section 54EC bond receipt within 6 months.
- Cross-tab the Section 70 set-off, Section 71 inter-head set-off, and Section 74 carry-forward of capital losses. LTCL set off only against LTCG; STCL set off against both. 8-year carry-forward under Section 74. See our Post 741 loss carry-forward deep-dive for the full set-off sequencing.
Frequently Asked Questions on Capital Gains Transition Under Section 536
Q1. If an asset was transferred in February 2026 but the consideration is received in instalments through 2027, which Act governs the capital gain?
The 1961 Act governs the capital gain. Section 45(1) charges the gain to tax in the previous year of transfer (FY 2025-26). The instalment receipt schedule does not shift the year of taxation. Section 536 sub-clauses 1 and 4 preserve this position for the previous year ending on or before March 31, 2026. Tax is paid in AY 2026-27 on the full consideration accrued under the agreement, regardless of when the cash actually flows.
Q2. Can I claim Section 54 exemption in AY 2026-27 and complete the new house construction in AY 2028-29 under the Income-tax Act 2025?
Yes, but the Section 54 conditions of the 1961 Act govern the lock-in window. The 3-year construction window, the 3-year transfer lock-in on the new house, and the CGAS deposit mechanics all follow the 1961 Act framework throughout. The successor section under the Income-tax Act 2025 does not retro-apply to the AY 2026-27 exemption already claimed. Failure to construct within 3 years revokes the exemption and the unutilised CGAS balance is taxed under Section 54(2) proviso in the previous year in which the 3 years expire.
Q3. Does the indexation benefit (CII) still apply for FY 2025-26 transfers?
Only for land and building acquired before July 23, 2024, and only in the hands of resident individuals and HUFs. Such taxpayers may elect the lower of (a) 12.5 per cent on LTCG without indexation or (b) 20 per cent on LTCG with indexation. For every other capital asset class, indexation under the second proviso to Section 48 does not apply for transfers on or after July 23, 2024. The CII for FY 2025-26 is 363.
Q4. What happens to the Section 47(xiiib) five-year lock-in if a private limited converts to LLP in March 2026?
The five-year lock-in conditions of Section 47(xiiib) continue to apply under the 1961 Act framework through FY 2030-31. Specifically: (a) no partner is paid any consideration other than profit share, (b) the original shareholders’ aggregate profit share remains at least 50 per cent for 5 years from conversion, (c) no profit-sharing reduction below 50 per cent for any erstwhile shareholder for 5 years, (d) the company’s turnover in any of the three preceding previous years did not exceed Rs 5 crore. Breach within the five-year window deems the conversion as a Section 45 transfer in the year of breach under Section 47A(4). For a March 2026 conversion, the lock-in window extends through March 2031, fully under Section 536 saving-clause continuity.
Q5. How are Section 50C stamp-duty additions on land/building handled if the agreement was signed in 2023 and registration completes in March 2026?
The stamp duty value as on the agreement date is taken as the deemed full value of consideration, per the proviso to Section 50C(1), if part consideration was received on or before the agreement date by way of account-payee cheque, bank draft, or electronic clearing system. Otherwise the stamp duty value on the date of registration governs. The 10 per cent tolerance band under the third proviso to Section 50C(1) applies. If declared consideration is within 10 per cent of stamp duty value, no Section 50C addition is made.
Q6. What ITR schedule and form should I use to report AY 2026-27 capital gains?
Schedule CG of ITR-2 (for individuals and HUFs with capital gains and no business income) or ITR-3 (for individuals and HUFs with both capital gains and business income), or Schedule CG of ITR-5 (firms and LLPs) or ITR-6 (companies). The schedule continues to use the 1961 Act capital-gains rubric through AY 2026-27 returns. CBDT has been notifying ITR forms each year between February and May; practitioners should track the AY 2026-27 form notifications and any schema changes published on incometax.gov.in. The corporate or non-corporate self-assessment payment, Section 234B / 234C interest, and Section 87A rebate eligibility are computed under the 1961 Act framework.
Practitioner Action Items Before March 31, 2026
- Map every client transfer transaction to a 1961 Act section and prepare a cutover-event log.
- Lock all Section 47 exempt-transfer documentation (NCLT orders, gift deeds, partition deeds, conversion certificates, scheme of arrangement) into the FY 2025-26 file.
- Confirm Section 54 to 54GB reinvestment plans, identify CGAS deposit needs by ITR due date, prepare the lock-in calendar.
- Run Section 50C / 50CA stamp-duty/FMV comparisons; consider Section 55A DVO references where the addition is material.
- Sequence Section 70/71/74 set-off / carry-forward of capital losses with the rest of the loss tranche (cross-reference Post 741 deep-dive).
- Verify Form 26AS and AIS for TDS reported under Sections 194-IA (property), 194Q (purchase of goods), 195 (non-resident), 196D (capital gains tax for FII).
Cross-References
This is the fourth instalment in the CBDT FAQ deep-dive series on the Income-tax Act 2025 transition. See companion posts: Post 723 (CBDT 99-page FAQ master), Post 732 (TDS Transition Deep-Dive), Post 737 (Section 148 Reassessment Deep-Dive), Post 741 (Loss Carry-Forward Deep-Dive).
Need Practitioner-Level Help With a Specific Capital Gains File?
If you have a client situation involving Section 47 amalgamation, demerger, LLP conversion, slump sale under Section 50B, JDA under Section 45(5A), large Section 54 / 54F / 54EC reinvestment plan, or any other capital gains transition question across the April 1, 2026 cutover, schedule a strategy session with the Tax Update India team. We will help you map the transaction, lock the cost continuity under Section 49, and document the file for AY 2026-27 closure.
Disclaimer: This article is for general information only and does not constitute legal or tax advice. Tax positions depend on facts of each case and may change with subsequent notifications. Cited section numbers refer to the Income-tax Act 1961 unless otherwise stated. Consult a qualified tax professional before acting on any information here.