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Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the actual transfer year.
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Taxability of business income from transfer of property held as stock-in-trade arises when the transferee receives possession in part performance of a written agreement for consideration and remains willing to perform. Receipt of the full consideration and delivery of possession complete the transfer; later registration of a conveyance incorporating the earlier agreement is procedural and does not create a fresh transaction. Accordingly, the deemed-consideration rule for stock-in-trade applies only in the previous year of the completed transfer, not in a later year solely because the conveyance was registered then. Income is attributable to the earlier assessment year, and the later-year addition does not survive.
Taxability of business income from transfer of property held as stock-in-trade arises when the transferee receives possession in part performance of a written agreement for consideration and remains willing to perform. Receipt of the full consideration and delivery of possession complete the transfer; later registration of a conveyance incorporating the earlier agreement is procedural and does not create a fresh transaction. Accordingly, the deemed-consideration rule for stock-in-trade applies only in the previous year of the completed transfer, not in a later year solely because the conveyance was registered then. Income is attributable to the earlier assessment year, and the later-year addition does not survive.
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