<h1>Advance Ruling: Capital Gains Triggered by Irrevocable GPA Execution, Not Agreement Date, as per Section 2(47) Interpretation.</h1> The advance ruling authority addressed the chargeability of income from capital gains in collaboration agreements under the Income Tax Act, 1961. It ruled that the date of entering into an agreement does not count as the transfer date if possession isn't immediately transferred. Clause (v) of section 2(47) doesn't require full payment for the transfer to be recognized. In the case examined, the execution of an irrevocable General Power of Attorney (GPA) marked the transfer date, as it allowed possession under the contract. This GPA was executed on May 8, 2006, making the capital gains applicable for the 2007-08 assessment year.