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All Case Studies
Real Estate Income Tax

Real Estate Group — Strategic Tax & Capital Gains

A multi-entity real estate group needed strategic positioning on Stock-in-Trade classification, Section 54F structuring, and CIT(A) appeals — we delivered all three with capital gains exemption preserved.

Client Type
Multi-entity group of construction companies
Industry
Real Estate & Construction
Engagement
ITR | Tax Audit | Capital Gains | CIT Appeals
Duration
Ongoing Engagement
The Challenge

What the engagement demanded.

A real estate group with multi-entity construction operations. Beyond compliance, this engagement required strategic tax positioning — classification of residential flats as Stock-in-Trade vs Capital Assets (with vastly different tax outcomes), Section 54 / 54F exemption planning where the group sold multiple properties but reinvested in a single residential property, intergroup transfer pricing for related-party transactions, CIT(A) appeals on contentious additions, and group-wide Tax Audit Report filing across entity types.

Our Approach

How we executed the engagement.

01

Classification Strategy

Detailed analysis of each residential unit — Stock-in-Trade (Sec 28) vs Capital Asset (Sec 45) — with documentation of intent and treatment.

02

Section 54/54F Structuring

Multi-property sale planning where exemption is claimed on a single qualifying reinvestment, with full lock-in compliance.

03

CIT(A) Appeals

Drafting grounds of appeal, paper book preparation, written submissions, and personal hearings.

04

Intergroup Transactions

Documentation of arm's length where applicable, with transfer pricing implications addressed.

05

Tax Audit Reports

Form 3CD with complete schedule disclosures, Form 3CA/3CB across all relevant entities.

06

Group-wide ITR

Consolidated filing tracker across PF, LLP, and Pvt Ltd, with intergroup eliminations.

Expertise Delivered

The capabilities we brought to bear.

Multi-entity ITR Preparation

Coordinated filing across Partnership Firms, LLPs, and Pvt Ltd entities with consolidated tracking.

Capital Gains Optimization

Section 54 / 54F structuring with multi-property sale and single-reinvestment planning.

Tax Audit Filing

Form 3CD with full Schedule disclosures, with quality review.

CIT Appeals

Drafting, evidence preparation, paper book compilation, and personal representation.

Stock-in-Trade Classification

Section 28 (business income) vs Section 45 (capital gains) analysis with documentation framework.

Group-wide Coordination

Tracker maintenance across entities, intergroup transactions, and consolidated planning.

Key Outcomes

The results we delivered.

Capital gains exemption preserved despite multi-property sale
Stock-in-Trade classification accepted by Assessing Officer / CIT(A)
Group ITRs filed without revision or rectification
Strategic tax positions documented for future scrutiny

At N D Savla & Associates, we don't just ensure compliance — we help you make smarter financial decisions with clarity and confidence.

— N D Savla & Associates

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