Construction for capital gains treatment where authority undertakes building and allottee holds title on allotment letter.

Investment in a flat allotted under the Self financing Scheme of the Delhi Development Authority is to be treated as construction for capital gains exemption purposes because the allottee obtains title on issuance of the allotment letter, the DDA performs construction on behalf of the allottee, instalment payments are secondary obligations, and the tentative cost of construction determined under the Scheme constitutes the cost of the new asset; the instalment mechanism does not change the transaction's character.

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