Registration completes a sale of immovable property; a later registration can bring the transfer within section 269C.

A compulsorily registrable sale of immovable property is completed only on registration, not on mere execution of the deed. Section 47 of the Registration Act gives a registered document retrospective operation for limited purposes, but it does not complete the transfer before registration. Accordingly, where section 269C of the Income-tax Act came into force before registration, the transfer fell within Chapter XX-A. The special definition of "instrument of transfer" in section 269A(f) was read as confined to transfers completed by registration, so the jurisdictional objection failed and the writ petition was dismissed with costs.

---

---

Issues: Whether a sale deed executed before the commencement of section 269C of the Income-tax Act, 1961 but registered after that provision came into force was outside the scope of Chapter XX-A, having regard to section 47 of the Registration Act and section 54 of the Transfer of Property Act.

Analysis: Section 47 of the Registration Act does not complete a sale before registration; it only gives a registered document operation from the date of execution for limited purposes. A sale of immovable property requiring registration is complete only when the instrument is registered. Until then, an intervening statutory right can affect the transfer. Here, the statutory power under section 269C came into force before registration, and the special definition of "instrument of transfer" in section 269A(f) confined the provision to transfers completed by registration under the Registration Act.

Conclusion: The transfer was subject to section 269C of the Income-tax Act, 1961, and the petitioner's jurisdictional objection failed.

Final Conclusion: The writ petition was not maintainable on the claimed ground and stood dismissed with costs.

Ratio Decidendi: For a compulsorily registrable sale of immovable property, the transfer is completed only on registration, and a statutory provision that comes into force before registration can validly apply notwithstanding prior execution of the deed.

---