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Corporate TaxArticle·20 August 2026

TDR has a cost

By J the App

Executive Summary

Is every TDR a self-generated asset with no cost of acquisition? Bangalore ITAT says no.

The taxpayer surrendered land to the BBMP and received TDR in return. 

That surrendered land gave the TDR an ascertainable cost, so its subsequent sale was taxable as capital gains. 

But the Tribunal also made sure the other side of the equation was respected, the attributable land cost must be allowedwhile computing the gain.”

Domain | Direct Tax | Corporate Tax

The Position

Transferable Develo...

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