https://www.taxtmi.com/caselaws?id=70520 An agreement of sale may amount to a transfer under section 2(47) of the Income-tax Act, 1961 where it creates enforceable obligations, restricts the owner's power of alienation, and confers possession and developmental rights on the purchaser. On the stated facts, the assessee's substantial proprietary rights were eroded and corresponding rights in favour of the purchaser were created, amounting to extinguishment of rights in the property. That characterization brought the transaction within section 2(47), attracted section 54B(ii), and made the capital gains chargeable, with the exemption unavailable. en-us Thu, 31 Mar 1977 00:00:00 +0530 Sat, 16 Apr 2011 15:52:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=70520 An agreement of sale may amount to a transfer under section 2(47) of the Income-tax Act, 1961 where it creates enforceable obligations, restricts the owner's power of alienation, and confers possession and developmental rights on the purchaser. On the stated facts, the assessee's substantial proprietary rights were eroded and corresponding rights in favour of the purchaser were created, amounting to extinguishment of rights in the property. That characterization brought the transaction within section 2(47), attracted section 54B(ii), and made the capital gains chargeable, with the exemption unavailable. Case-Laws Income Tax Thu, 31 Mar 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=70520