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    <title>1987 (9) TMI 82 - ITAT DELHI-A</title>
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    <description>A collaboration arrangement over leasehold land and an existing structure does not, by itself, constitute a transfer of a capital asset under section 2(47) of the Income-tax Act, 1961, where no registered conveyance is executed and the property is not actually conveyed. The arrangement is treated as a permissive licence to enter and construct, not as a sale or lease, and the assessee&#039;s substantive rights in the property are not completely extinguished. Amounts received in advance or as security for a contemplated future transfer of yet-to-emerge built-up space do not create capital gains until an effective transfer occurs.</description>
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    <pubDate>Tue, 22 Sep 1987 00:00:00 +0530</pubDate>
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      <title>1987 (9) TMI 82 - ITAT DELHI-A</title>
      <link>https://www.taxtmi.com/caselaws?id=63002</link>
      <description>A collaboration arrangement over leasehold land and an existing structure does not, by itself, constitute a transfer of a capital asset under section 2(47) of the Income-tax Act, 1961, where no registered conveyance is executed and the property is not actually conveyed. The arrangement is treated as a permissive licence to enter and construct, not as a sale or lease, and the assessee&#039;s substantive rights in the property are not completely extinguished. Amounts received in advance or as security for a contemplated future transfer of yet-to-emerge built-up space do not create capital gains until an effective transfer occurs.</description>
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      <pubDate>Tue, 22 Sep 1987 00:00:00 +0530</pubDate>
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