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Tax on Gifting & Inheriting Unlisted Shares

Section 56(2)(x), relative exemptions, and how cost basis and holding period carry over

28 Jun 20266 min read

# Tax on Gifting & Inheriting Unlisted Shares

Unlisted shares often move within families — parents gifting to children, shares passing on through a will, founders transferring stakes to relatives. Each of these has distinct tax consequences, and the rules differ depending on whether the transfer is a gift during lifetime or an inheritance on death.

This article covers both: when a gift of unlisted shares is taxable, who is exempt, and how the original cost and holding period carry over to the new owner.

Disclaimer: This is general educational content, not tax advice. Gift and inheritance situations are fact-specific, and documentation matters a great deal. Consult a chartered accountant before acting on a specific transfer.

Two Separate Taxes to Keep Apart

There is no longer any standalone "gift tax" or "estate duty" in India. Instead:

  • A gift of unlisted shares can be taxed in the recipient's hands under Section 56(2)(x) as income from other sources.
  • A later sale of the gifted or inherited shares triggers capital gains tax, using the carried-over cost and holding period.

Inheritance on death is itself not a taxable event — neither for the estate nor the heir. Tax only arises when the heir eventually sells.

When a Gift of Shares Is Taxable — Section 56(2)(x)

If you receive unlisted shares without consideration (a pure gift) and the aggregate fair market value of property received without consideration in the year exceeds ₹50,000, the entire FMV is taxable as income from other sources.

If you receive shares for inadequate consideration (you pay less than FMV), and the shortfall exceeds ₹50,000, that shortfall (FMV minus what you paid) is taxable.

The FMV of unlisted shares for this purpose is computed under Rule 11UA — broadly a net-asset-value based valuation. (See our separate article on Rule 11UA and Section 56(2)(x).)

The Relative Exemption

Section 56(2)(x) does not apply if the gift comes from a relative, as specifically defined. The exemption is unlimited — there is no value cap when the donor is a relative. Defined relatives include:

  • Spouse.
  • Brother or sister, and their spouses.
  • Brother or sister of either parent (uncles and aunts by blood).
  • Any lineal ascendant or descendant (parents, grandparents, children, grandchildren), and their spouses.
  • Any lineal ascendant or descendant of the spouse, and their spouses.

Gifts are also exempt when received:

  • On the occasion of the recipient's marriage.
  • Under a will or inheritance.
  • In contemplation of the death of the donor.

Note that cousins, friends, and most distant relations are not "relatives" for this purpose — a gift of unlisted shares from them above ₹50,000 FMV is taxable in your hands.

Clubbing — A Trap for Spouse and Minor Gifts

Even where the gift itself is exempt, clubbing provisions under Section 64 can attribute future income to the donor:

  • Shares gifted to a spouse or minor child: any capital gain on their later sale may be clubbed back into the donor's income.
  • This does not change who owns the shares, but it changes whose return reports the gain.

This is a frequent surprise in family transfers and should be planned for explicitly.

Cost Basis for Inherited and Gifted Shares — Section 49(1)

When shares pass by gift, will, or inheritance, Section 49(1) says the recipient's cost of acquisition is the cost to the previous owner. You do not get a fresh "stepped-up" cost equal to the value on the date of transfer.

  • If the previous owner acquired the shares before 1 April 2001, you may substitute the FMV as on 1 April 2001 as the cost.
  • Any cost of improvement incurred by the previous owner also carries over.

### Worked Example

  • Your mother bought unlisted shares in 2015 for ₹2 lakh.
  • She gifts them to you in 2024. You sell them in 2025 for ₹10 lakh.
  • Your cost of acquisition is ₹2 lakh (her cost), not the 2024 value.
  • Capital gain = ₹10 lakh − ₹2 lakh = ₹8 lakh.

Holding Period Carries Over Too

For these transfers, the previous owner's holding period is included in yours when deciding short-term versus long-term. This is one of the most valuable features of the rules.

  • Mother held the shares from 2015 to 2024 (long-term).
  • You sell within a few months of receiving them in 2024.
  • Because her period is added, the combined holding far exceeds 24 months — so your gain is long-term, taxed at the concessional LTCG rate (12.5% under the post-23 July 2024 regime) rather than at your slab rate.

Without the carry-over, a quick post-gift sale would have looked short-term.

Documentation to Keep

  • A gift deed (for lifetime gifts) clearly identifying the shares, donor, and donee.
  • Proof of the donor's original cost and date of acquisition.
  • The will, succession certificate, or probate for inherited shares.
  • Demat transmission/transfer records showing the change of ownership.
  • A valuation under Rule 11UA where a taxable gift is involved.

*Published by the Polemarch editorial team. Not tax advice — consult a chartered accountant.*

Frequently asked

It can be. Under Section 56(2)(x), if you receive unlisted shares without consideration (a gift) and their fair market value exceeds ₹50,000, the whole FMV is taxable as 'income from other sources' in your hands — unless the gift is from a defined relative or falls under another exemption (such as on marriage, under a will, or by inheritance). Gifts from relatives are fully exempt regardless of value.

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