GPFE Hosuing Co-operative Society Ltd Vs ITO (ITAT Bangalore)
The Bangalore Bench of the Income Tax Appellate Tribunal considered an appeal by GPFE Housing Co-operative Society Ltd. against the NFAC order dated 09.02.2026 for AY 2015-16. Grounds 1, 2 and 3 were dismissed as not pressed. The surviving dispute concerned the computation of long-term capital gains on two properties sold during FY 2014-15 for aggregate consideration of Rs. 2.52 crore. The assessee had claimed the receipts as exempt capital receipts, but the Assessing Officer rejected the claim and treated the entire sale consideration as long-term capital gain after adopting the cost of acquisition at NIL because the assessee could not furnish old acquisition records. The NFAC confirmed the assessment.
Before the Tribunal, the assessee submitted that the two properties were identifiable old immovable properties and that the inability to produce complete historical records could not establish that their cost was NIL. One property, sold for Rs. 1.78 crore, was connected with sites released by the Bangalore Development Authority in 1977, while the other, sold for Rs. 74 lakh, was recorded in the sale deed as having been purchased by the society on 17.02.1994. The assessee relied upon Sections 45, 48 and 55 and furnished computations using reverse indexation/time-gap methodology to estimate historical cost or fair market value. The Revenue maintained that the assessee had failed to furnish supporting evidence but accepted that additional material could be examined by the AO.
