This compilation indexes 12 orders — spanning ITAT benches and several High Courts — in which Section 48 of the Income Tax Act, 1961, or a closely associated provision, was cited or engaged. The rulings were pronounced between December 2024 and June 2026 and are drawn from the TaxNoticeAI structured legal corpus. The collection is intended as a starting-point reference for in-house tax teams, Big-4 associates, and law firm researchers who need a consolidated view of how Section 48 has featured across different forums and fact-patterns during this period.

Research index only. This page catalogues orders for identification and research purposes. It does not constitute legal or tax advice. Readers must consult the full text of each judgment and qualified counsel before drawing any conclusion about their own matters.

The statutory framework in one paragraph

Section 48 of the Income Tax Act, 1961 prescribes the mode of computation of income chargeable under the head "Capital Gains." It provides that the income chargeable shall be computed by deducting from the full value of consideration received or accruing as a result of the transfer of the capital asset: (i) the expenditure incurred wholly and exclusively in connection with such transfer, and (ii) the cost of acquisition of the asset and any cost of improvement thereto. The section also contains the proviso for computing indexed cost of acquisition and indexed cost of improvement by applying the Cost Inflation Index notified by the Central Government, subject to the conditions and exclusions stated therein. Separate computational rules apply to non-residents and to certain categories of assets under the provisos to the section.

The 12 rulings

1. Sashi Parvatha Reddi,Usa vs ADIT., Intl Taxation -2, Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 10 June 2026
Sections engaged: 112(1)(c), 143(2), 143(3), 2(47), 250(6), 271(1)(c), 48
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1486/Hyd/2025) was filed by the assessee against the order of the Commissioner of Income Tax (Appeals)-10, Hyderabad, dated 21/08/2025, which in turn arose from an assessment order passed under section 143(3) for Assessment Year 2016-17. The assessee, a US-based individual with PAN ADYPR7774H, raised grounds before the Tribunal assailing the CIT(A)'s findings; the substantive disposition is not captured in the available source preview.

2. Ramatas Revathi,Karaikudi vs ITO, Ward-1,, Karaikudi

Bench: Income Tax Appellate Tribunal - Chennai
Date: 10 June 2026
Sections engaged: 48
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 4128/Chny/2025) was filed by the assessee against the order of the Commissioner of Income Tax (Appeals), NFAC, Delhi, dated 18.11.2025, for Assessment Year 2015-16. A substantive ground raised by the assessee, as reflected in the source preview, was that construction details relating to land — which form part of the sale deed — could not be treated as additional evidence to deny the benefit of indexation in the computation of capital gains under Section 48.

3. Deputy Commissioner Of Income Tax vs Somnath Vaijnath Sakre, Aurangabad

Bench: Income Tax Appellate Tribunal - Pune
Date: 16 April 2026
Sections engaged: 48
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1942/PUN/2024) relating to Assessment Year 2013-14 was noted as the second round of litigation before the Tribunal. Per the source preview, the assessee is an individual engaged in manufacturing of plastic water tanks and plastic milk cans under the name M/s. Shree Maruti Udyog, who had filed a return on 31.10.2013 declaring total income of Rs. 5,55,53,700/-; the case was subsequently selected for scrutiny after initial processing. The Tribunal's final disposition on the Section 48 issue is not captured in the available preview.

4. Accurate Auctioneers vs Union Of India And Ors

Bench: Delhi High Court
Date: 3 February 2026
Sections engaged: 48
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter (LPA 233/2023) arose from a writ petition filed by Accurate Auctioneers challenging a Circular dated 3 December 2018 issued by the Central Board of Indirect Taxes and Customs; the writ petition had been dismissed by a Single Judge on 5 September 2022, and the appellant was before the Division Bench in the letters patent appeal. Per the source preview, the impugned Circular dealt with a revised procedure for expeditious disposal of unclaimed/uncleared cargo lying with custodians under Section 48 of the Customs Act, 1962 — the "Section 48" cited in this case therefore refers to the Customs Act, 1962, not the Income Tax Act, 1961; researchers should note this distinction when using this entry.

5. Smt. Asha Mallikarjuna Hegde vs The Authorised Officer And The

Bench: Karnataka High Court
Date: 16 December 2025
Sections engaged: 48
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter was heard by the Karnataka High Court at Bengaluru, with the writ petitions (WP No. 6398/2018 and connected matters) filed by petitioners including Sri Thingale Vikramarjuna Hegde and Ms. Spoorthi Rai. The source preview is primarily procedural in nature, setting out the identity of the parties and the petition details; the substantive issue and final disposition are not available from the source preview.

6. Mashooda M.T.P vs The Commissioner

Bench: Kerala High Court
Date: 4 December 2025
Sections engaged: 47, 48
Outcome: Outcome not specified in source
Procedural / substantive ground: This was a bail application (B.A. No. 12138 of 2025) filed under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, by the petitioner/accused in a crime registered by Air Customs, Calicut International Airport. The matter arose before the Kerala High Court and is primarily criminal/bail in nature; the "Section 48" reference in the sections cited likely pertains to customs or a related enactment rather than Section 48 of the Income Tax Act. Researchers should verify the full order before treating this entry as an income-tax capital-gains authority.

7. Sri Bipul Kumar Das Alias Bipul Das vs Union Of India

Bench: Gauhati High Court
Date: 25 November 2025
Sections engaged: 48, 37
Outcome: Outcome not specified in source
Procedural / substantive ground: This was a bail application (Bail Appln./3200/2025) filed under Section 483 of the BNSS 2023 by the petitioner, who had been detained since 05.09.2024 in connection with NDPS Case No. 59/2025 arising out of Customs Case No. 01/CL/NARC/AS/GAU/2024-25. Per the source preview, the accusation related to alleged stocking of narcotic substances at the petitioner's residence. This matter is criminal/bail in nature involving customs and NDPS law; researchers should verify the relevance of the "Section 48" citation to the Income Tax Act before relying on this entry for income-tax research.

8. Md. Mofazzular Rahman & Ors vs Md. Sarfaraz Alam & Ors

Bench: Calcutta High Court
Date: 10 November 2025
Sections engaged: 45, 48
Outcome: Outcome not specified in source
Procedural / substantive ground: The application (G.A. No. 8 of 2023 in C.S. (Com) No. 158 of 2024, old No. CS 174 of 2019) was filed by defendant no. 1 before the Commercial Division of the Calcutta High Court, praying for recording the death of plaintiff no. 1 (who died on 16th June 2023 during the pendency of the suit) and for substitution of his legal heirs as plaintiffs. The source preview is procedural in nature, relating to substitution in a commercial suit; the income-tax nexus of the Section 48 citation is not apparent from the available preview, and researchers should consult the full order.

9. Page No.# 1/39 vs Shri Shashi Kumar Choudhary And Anr

Bench: Gauhati High Court
Date: 24 September 2025
Sections engaged: 47, 48
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter (Crl.Rev.P./224/2025) was filed by the Union of India, represented by the Intelligence Officer of the Directorate General of Goods and Services Tax Intelligence, Guwahati Zonal Unit, against the respondents who were proprietors of GST-registered enterprises. Per the source preview, the application was filed under Section 438 read with another provision and arose in a GST intelligence context. Researchers should note that the "Section 48" citation here likely pertains to a GST or criminal procedural enactment rather than Section 48 of the Income Tax Act, and should verify the full order accordingly.

10. Hriday Ram vs A.D.M. Kanoon Vyavastha/ D.D.C

Bench: Allahabad High Court
Date: 16 May 2025
Sections engaged: 48
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (Writ-B No. 972 of 2004) was filed before the Lucknow Bench of the Allahabad High Court, challenging an order dated 03.09.2004 passed by the Additional District Magistrate (Law and Order)/Deputy Director of Consolidation, District Faizabad (now Ayodhya). Per the source preview, the Section 48 cited is Section 48 of the U.P. Consolidation of Holdings Act, 1953 — not Section 48 of the Income Tax Act, 1961. The petition related to land consolidation proceedings concerning 0.100 hectare of land at Village Sihipur. Researchers should be aware that this ruling does not engage income-tax capital-gains computation.

11. Palani vs /

Bench: Madras High Court
Date: 9 January 2025
Sections engaged: 48
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P.(MD) No. 559 of 2025) was filed before the Madurai Bench of the Madras High Court under Article 226 of the Constitution of India, challenging a Refusal Check Slip (RFL/Puliyangudi/69/2024 dated 19.12.2024) issued by the Sub Registrar, Puliyankudi, Tenkasi District, refusing to register a sale deed dated 18.12.2024 relating to the petitioner's undivided share in Plot No. 63B. The matter is a property registration dispute; the "Section 48" citation does not appear to engage the Income Tax Act's capital-gains computation provisions, and researchers should verify the statutory basis before treating this as an income-tax authority.

12. Bankipore Club Ltd., Collectorate vs The State Of Bihar

Bench: Patna High Court
Date: 19 December 2024
Sections engaged: 47, 48
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals (Miscellaneous Appeal No. 210 of 2008 and Miscellaneous Appeal No. 975 of 2010) were filed before the Patna High Court by Bankipore Club Ltd. against the State of Bihar, the Commissioner of Commercial Taxes, and the Deputy Commissioner of Commercial Taxes. Per the source preview, the respondents include commercial-tax authorities of Bihar, indicating that the "Section 47" and "Section 48" references likely pertain to the Bihar commercial-tax or VAT legislation rather than the Income Tax Act. Researchers should confirm the statutory basis from the full order before relying on this ruling for income-tax purposes.

Patterns across these 12 rulings

Heterogeneous "Section 48" citations. A notable feature of this dataset is that the label "Section 48" does not uniformly refer to Section 48 of the Income Tax Act, 1961. Across the 12 orders, the same section-number tag appears in contexts involving the Customs Act, 1962 (case 4), the NDPS/Customs criminal regime (case 7), the U.P. Consolidation of Holdings Act, 1953 (case 10), Bihar commercial-tax legislation (case 12), property registration (case 11), and GST intelligence proceedings (case 9). Researchers must identify the parent statute before drawing income-tax conclusions.
Income-tax capital-gains computation is the core theme only for the ITAT matters. Among the 12 rulings, the clearest engagement with Section 48 of the Income Tax Act in its capital-gains computation sense is found in the ITAT matters — particularly cases 1, 2, and 3 — where assessment of capital gains, indexation benefit, and related procedural challenges to AO and CIT(A) orders are the subject matter.
Indexation-benefit disputes surface as a recurring assessee grievance. Case 2 (Ramatas Revathi, ITAT Chennai, AY 2015-16) explicitly raises the ground that construction details forming part of a sale deed cannot be treated as additional evidence to deny the indexation benefit under Section 48. This reflects a pattern seen in capital-gains litigation where the characterisation and admissibility of evidence bearing on cost computation is contested.
Second-round ITAT litigation indicates unresolved factual complexity. Case 3 (DCIT vs. Somnath Vaijnath Sakre, ITAT Pune, AY 2013-14) was expressly noted as the second round of litigation before the Tribunal, suggesting that Section 48 computation disputes can involve remands and successive adjudicatory rounds when the underlying facts — such as the nature of assets or the components of cost — are not straightforwardly established.
Outcome data is absent across all 12 cases. Every entry in this compilation carries the tag "Outcome not specified in source," meaning the operative direction of each order (whether the appeal was allowed, dismissed, or partly allowed) cannot be confirmed from the available preview. Users must retrieve and read the full judgments to determine the dispositive outcome before citing any of these orders in submissions or opinions.

How to use this compilation

This index is designed as a first-pass identification tool. When a case heading and citation are identified here, the next step is always to retrieve the full text of the judgment from the source portal (indiankanoon.org, the relevant High Court's official website, or the ITAT e-Filing portal) and read the complete order. The text previews reproduced here are truncated extracts from the source corpus and do not contain the dispositive paragraphs or the full reasoning. No holding should be attributed to any case in this list based solely on the information above.

Researchers should also verify whether each order has been the subject of a stay, reversal, or further appeal. An ITAT order may be challenged before the jurisdictional High Court under Section 260A of the Income Tax Act; a High Court single-bench order may be in appeal before a Division Bench. Currency of precedent is critical: an order pronounced in 2025 or 2026 may already have been stayed or overruled by the time you access this index. The TaxNoticeAI corpus is updated periodically, but it is not a real-time tracker of appeal status.

Finally, for any matter touching on capital-gains computation under Section 48, researchers should check for applicable CBDT circulars, notifications prescribing the Cost Inflation Index for the relevant financial year, and any Finance Act amendments that may have modified the proviso structure of the section. Statutory amendments can alter the applicable computational rule even where the judicial precedent on a particular point appears settled.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 48 Income Tax & Related Rulings: 12-Case Index (2024–2026)