https://www.taxtmi.com/caselaws?id=63516 An agreement to sell did not by itself transfer title or extinguish rights where it remained conditional and contemplated refund and damages if the sale deed was not executed. Applying section 47 of the Registration Act and section 2(47) of the Income-tax Act, the transfer occurred only on execution and registration of the sale deed. As that date fell after 28-2-1979, the amended section 54E regime applied and required investment in National Rural Development Bonds. Deposit in a nationalised bank did not meet that statutory condition, so exemption under section 54E was unavailable and the capital gains were taxable. en-us Tue, 29 Jul 1986 00:00:00 +0530 Mon, 31 Jan 2011 14:42:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63516 An agreement to sell did not by itself transfer title or extinguish rights where it remained conditional and contemplated refund and damages if the sale deed was not executed. Applying section 47 of the Registration Act and section 2(47) of the Income-tax Act, the transfer occurred only on execution and registration of the sale deed. As that date fell after 28-2-1979, the amended section 54E regime applied and required investment in National Rural Development Bonds. Deposit in a nationalised bank did not meet that statutory condition, so exemption under section 54E was unavailable and the capital gains were taxable. Case-Laws Income Tax Tue, 29 Jul 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63516