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    <title>1991 (3) TMI 203 - ITAT DELHI-D</title>
    <link>https://www.taxtmi.com/caselaws?id=64529</link>
    <description>Rights under a hotel-project licence deed were treated as a capital asset when assigned for consideration, and the transfer was taxed as short-term capital gains because the rights were held only from the 1981 licence deed, not from an earlier inchoate claim. The licence created only a permission to use, not an interest in immovable property, so registration was not required on that footing. The receipt was not treated as business income or an adventure in the nature of trade, as there was no dominant profit-making intention in the assessee&#039;s acquisition and transfer of the licence rights. Ancillary items were partly remanded, partly sustained, and partly allowed.</description>
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    <pubDate>Tue, 05 Mar 1991 00:00:00 +0530</pubDate>
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      <title>1991 (3) TMI 203 - ITAT DELHI-D</title>
      <link>https://www.taxtmi.com/caselaws?id=64529</link>
      <description>Rights under a hotel-project licence deed were treated as a capital asset when assigned for consideration, and the transfer was taxed as short-term capital gains because the rights were held only from the 1981 licence deed, not from an earlier inchoate claim. The licence created only a permission to use, not an interest in immovable property, so registration was not required on that footing. The receipt was not treated as business income or an adventure in the nature of trade, as there was no dominant profit-making intention in the assessee&#039;s acquisition and transfer of the licence rights. Ancillary items were partly remanded, partly sustained, and partly allowed.</description>
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      <pubDate>Tue, 05 Mar 1991 00:00:00 +0530</pubDate>
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