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Capital gain - unregistered agreement - transfer of capital asset u/s 2(47) - real owner - deemed owner - CIT(A) has diverted his mind to a wrong provision of law and diverted himself from the ratio decided in Balbir Singh Maini. In the present case, the controversy between parties is precisely for “Income from Business” head and that too whether or not M/s Govind can be said to be owner of land on the basis of unregistered agreement. - The answer is NO - AT