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    <title>2013 (9) TMI 229 - ITAT AMRITSAR</title>
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    <description>A joint development arrangement was treated as a transfer where the developer obtained effective possession and control through an irrevocable special power of attorney and the parties&#039; conduct, bringing the transaction within sections 2(47)(v) and 2(47)(vi) even though the arrangement was unregistered. Capital gains were held taxable in the year of transfer on the full consideration accruing under sections 45 and 48, including the value of proposed flats and not merely cash actually received. Reopening under sections 147 and 148 was also sustained on the basis of material indicating escapement of income, and later cancellation claims or the plea of notional income did not defeat the charge.</description>
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      <title>2013 (9) TMI 229 - ITAT AMRITSAR</title>
      <link>https://www.taxtmi.com/caselaws?id=236796</link>
      <description>A joint development arrangement was treated as a transfer where the developer obtained effective possession and control through an irrevocable special power of attorney and the parties&#039; conduct, bringing the transaction within sections 2(47)(v) and 2(47)(vi) even though the arrangement was unregistered. Capital gains were held taxable in the year of transfer on the full consideration accruing under sections 45 and 48, including the value of proposed flats and not merely cash actually received. Reopening under sections 147 and 148 was also sustained on the basis of material indicating escapement of income, and later cancellation claims or the plea of notional income did not defeat the charge.</description>
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