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    <title>1988 (4) TMI 107 - ITAT DELHI-C</title>
    <link>https://www.taxtmi.com/caselaws?id=64203</link>
    <description>Section 54 relief was considered unavailable where the assessee had paid consideration and taken possession of a flat, but no registered sale deed or conveyance had been executed. The commentary states that an agreement to sell and possession, even with the protection of part performance under section 53A of the Transfer of Property Act, do not by themselves confer title; the later deeming rule in section 27(iiia) was not applicable for the relevant assessment year. On the house-property issue, the text explains that without legal ownership the flat could not be treated as owned by the assessee, so the notional income was not assessable as income from house property.</description>
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    <pubDate>Wed, 20 Apr 1988 00:00:00 +0530</pubDate>
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      <title>1988 (4) TMI 107 - ITAT DELHI-C</title>
      <link>https://www.taxtmi.com/caselaws?id=64203</link>
      <description>Section 54 relief was considered unavailable where the assessee had paid consideration and taken possession of a flat, but no registered sale deed or conveyance had been executed. The commentary states that an agreement to sell and possession, even with the protection of part performance under section 53A of the Transfer of Property Act, do not by themselves confer title; the later deeming rule in section 27(iiia) was not applicable for the relevant assessment year. On the house-property issue, the text explains that without legal ownership the flat could not be treated as owned by the assessee, so the notional income was not assessable as income from house property.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Wed, 20 Apr 1988 00:00:00 +0530</pubDate>
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