Section 47(vi) Amalgamation is Tax-Neutral, Indexation Runs from Year of Use, Not Occupancy Certificate: ITAT:

Section 47(vi) Amalgamation is Tax-Neutral, Indexation Runs from Year of Use, Not Occupancy Certificate: ITAT

ITAT held in Boyance Infrastructure that an amalgamation under Section 47(vi) is tax-neutral and indexation for capital gains begins from the year the property was first put to use and earned rent, not from the Occupancy Certificate date.

ITAT Rejects AO’s Reliance on Occupancy Certificate Date

authorKhush TrivedidateMay 28, 2026
Last update on Jul 23, 2026
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Section 47(vi) Amalgamation is Tax-Neutral, Indexation Runs from Year of Use, Not Occupancy Certificate: ITAT

ITAT held in Boyance Infrastructure that an amalgamation under Section 47(vi) is tax-neutral and indexation for capital gains begins from the year the property was first put to use and earned rent, not from the Occupancy Certificate date.

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Khush Trivedi

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