Execution date controls applicable transfer-tax regime; later Form No. 37-I filing does not change the governing chapter.

The governing provision for an agreement to transfer immovable property is determined by the date of execution of the agreement, not by a later filing of Form No. 37-I. On the stated facts, an agreement executed on 11 June 1986 fell under Chapter XX-A because Chapter XX-C came into force only on 1 October 1986. The later statutory form filing under Rule 48L(2) did not alter the applicable regime. The note therefore treats Chapter XX-C as inapplicable and Chapter XX-A as the operative provision for that transaction.

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Issues: Whether Chapter XX-A or Chapter XX-C of the Income-tax Act, 1961 applied to the agreement executed on 11 June 1986, and whether filing of Form No. 37-I under Rule 48L(2) of the Income-tax Rules, 1962 affected the applicable provision.

Analysis: The agreement preceded the effective date of Chapter XX-C, which came into force on 1 October 1986. The controlling date was the date of execution of the agreement, not the later filing of Form No. 37-I. On the same facts, the earlier decision treated Chapter XX-A as the applicable provision and held that invocation of Chapter XX-C was unsustainable. The connected petition involved the same dates and the same legal question.

Conclusion: Chapter XX-A applied, Chapter XX-C was inapplicable, and the filing of Form No. 37-I was inconsequential.

Final Conclusion: The writ petitions succeeded on the basis that the transfer agreement was governed by the earlier statutory regime in force on the date of execution.

Ratio Decidendi: The applicable provision is determined by the date on which the agreement is executed, and a subsequent statutory form filing does not alter the statutory regime governing that transaction.

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