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    <title>2014 (8) TMI 636 - ANDHRA PRADESH HIGH COURT</title>
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    <description>Section 2(47) of the Income-tax Act treats a transfer as taking place when a development agreement is coupled with possession in part performance under section 53A of the Transfer of Property Act. Payment of consideration on the date of the agreement is not required; the critical elements are a written contract, delivery of possession, and conduct showing performance or willingness to perform. On the facts described, the agreement and possession occurred in the same previous year, so capital gains were taxable in that year and later receipt of consideration did not defer taxability.</description>
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