Skip to main content

Property co-ownership doesn’t mean joint I-T liability

If the spouse has not invested in a property and is merely a co-holder, then on sale of such property, she cannot be liable for tax on capital gains, the Mumbai Income-Tax Appellate Tribunal (ITAT) has recently ruled.

The ITAT order will help many taxpayers as married couples are increasingly opting for property registration in joint names, even if only one of them is the investor.
Anil Harish, an advocate specializing in real estate, said: "Co-holding of property is popular. Often the name of a spouse (say wife) is added to provide a sense of comfort, to ensure ease of succession on death of the partner or other reasons such as facilitating voting in a general body meeting of the housing society."
The ITAT gave the order on Wednesday while hearing a case of a medical professional, Vandana Bhulchandani.

An income-tax (I-T) officer, based on information in his possession, noted that Bhulchandani had not disclosed the capital gains arising from the Rs 2.12-crore sale of a property in Parel that she jointly held with her husband in her I-T return for the financial year 2008-09.
She informed the I-T officer that her husband had made the entire investment and the property was reflected in his books of accounts—from the date of purchase till the date of sale. The officer also observed that Bhulchandani's husband did not incur any I-T liability on the capital gains arising from the sale—the husband had set off the short-term capital gains arising from the Parel property sale against the short-term capital losses incurred by him on the sale of shares. Under the I-T Act, short-term capital losses can be set off against capital gains arising in the same financial year and only the surplus, if any, is taxable.

But the I-T officer claimed that the entire arrangement was done to avoid tax payment and held Bhulchandani to be liable for 50% of the total short-term capital gains arising from the property sale and added Rs 45.38 lakh to her taxable income. Short-term capital gains are taxed at the applicable I-T slab rates, which depending on an individual's income varies between 10% and 30% in addition to applicable surcharge and cess.
Bhulchandani approached the commissioner of income-tax (appeals) who directed deletion of the addition. The I-T officer then filed an appeal before the ITAT. But the tribunal took into cognizance that the husband had bought the property, which was duly reflected in his books of accounts, and had also disclosed the details of the sale in his I-T return and thus, dismissed the appeal.

Comments

Popular posts from this blog

MACT - Permanent disability - calculate - compensation - Supreme Court - Part 2

1) C. K. Subramonia Iyer vs. T. Kunhikuttan Nair - AIR 1970 SC 376 2) R. D. Hattangadi vs. Pest Control (India) Ltd. - 1995 (1) SCC 551 3) Baker vs. Willoughby - 1970 AC 467 4) Arvind Kumar Mishra v. New India Assurance Co.Ltd. - 2010(10) SCALE 298 5) Yadava Kumar v. D.M., National Insurance Co. Ltd. - 2010 (8) SCALE 567) 5. The heads under which compensation is awarded in personal injury cases are the following : Pecuniary damages (Special Damages) (i) Expenses relating to treatment, hospitalization, medicines, transportation, nourishing food, and miscellaneous expenditure. (ii) Loss of earnings (and other gains) which the injured would have made had he not been injured, comprising : (a) Loss of earning during the period of treatment; (b) Loss of future earnings on account of permanent disability. (iii) Future medical expenses. Non-pecuniary damages (General Damages) (iv) Damages for pain, suffering and trauma as a consequence of the injuries. (v) Loss of ...

Full & Final payment - No dues certificate - end of contract

Whether after the contract comes to an end by completion of the contract work and acceptance of the final bill in full and final satisfaction and after issuance a `No Due Certificate' by the contractor Supreme Court of India Supreme Court of India R.L. Kalathia & Co. vs State Of Gujarat on 14 January, 2011 Author: P Sathasivam Bench: P. Sathasivam, B.S. Chauhan IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION CIVIL APPEAL NO. 3245 OF 2003 R.L. Kalathia & Co Appellant(s) Versus State of Gujarat .... Respondent(s) JUDGMENT P. Sathasivam, J. 1) This appeal is directed against the judgment and final order dated 07.10.2002 passed by the Division Bench of the High Court of Gujarat whereby the High Court set aside the judgment and decree dated 14.12.1982 passed by the Civil Judge, (S.D.), Jamnagar directing the State Government to pay a sum of Rs.2,27,758/- with costs and interest and dismissed the Civil Suit as well as cross objections filed by the a...

Distinction between “Loss to the Estate” and “Loss of Estate”

A subtle but fundamental distinction between “Loss of Estate” and “Loss to the Estate” was discussed in Omana P.K. and others v. Francis Edwin and others (2011 (4) KLT 952). This Judgment was challenged before the Apex Court, which has now dismissed the Appeal. The question raised in this case, was whether a certain sum which the dependants received as compensation for untimely death of Judgment debtor in a motor accident is attachable in Execution Proceedings. In this case, Justice Thomas P. Joseph speaking for the Kerala High Court had held the following (relying on The Chairman, A.P.S.R.T.C, Hyderabad vs. Smt. Shafiya Khatoon and Others) Capitalized value of the income spent on the dependents, subject to relevant deductions, is the pecuniary loss sustained by the members of his family through his death. The capitalized value of his income, subject to relevant deductions, would be the loss caused to the estate by his death. In other words, what amount the dependents would have got le...