https://www.taxtmi.com/caselaws?id=252528 Possession delivered under an MOU can amount to a transfer under section 2(47)(v) of the Income-tax Act when the arrangement is of the kind protected by section 53-A of the Transfer of Property Act, so receipts linked to transfer-related rights may be treated as consideration for transfer. Even so, where the underlying asset is agricultural land and that character remains undisputed in substance, the resulting income is not taxable as capital gains. The discussion also notes that revision under section 263 is not sustainable where the core finding that the land was agricultural cannot be displaced on the facts found. en-us Tue, 26 Aug 2014 00:00:00 +0530 Wed, 18 Feb 2015 18:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252528 Possession delivered under an MOU can amount to a transfer under section 2(47)(v) of the Income-tax Act when the arrangement is of the kind protected by section 53-A of the Transfer of Property Act, so receipts linked to transfer-related rights may be treated as consideration for transfer. Even so, where the underlying asset is agricultural land and that character remains undisputed in substance, the resulting income is not taxable as capital gains. The discussion also notes that revision under section 263 is not sustainable where the core finding that the land was agricultural cannot be displaced on the facts found. Case-Laws Income Tax Tue, 26 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252528