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    <title>2014 (11) TMI 143 - ITAT AHMEDABAD</title>
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    <description>For capital gains purposes, transfer was treated as occurring when the agreement to sell was executed on 31.03.2008, consideration was substantially received, and possession was handed over, even though registration followed later. The Income-tax Act concept of transfer under section 2(47), read with section 45, was applied separately from the strict conveyancing rule under the Transfer of Property Act. The earlier capital gains authorities were followed, and the later GPA line of decisions was held inapplicable on these facts because the transaction had already been acted upon and completed between the parties. Accordingly, the gain was not taxable in assessment year 2009-10.</description>
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      <title>2014 (11) TMI 143 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=252826</link>
      <description>For capital gains purposes, transfer was treated as occurring when the agreement to sell was executed on 31.03.2008, consideration was substantially received, and possession was handed over, even though registration followed later. The Income-tax Act concept of transfer under section 2(47), read with section 45, was applied separately from the strict conveyancing rule under the Transfer of Property Act. The earlier capital gains authorities were followed, and the later GPA line of decisions was held inapplicable on these facts because the transaction had already been acted upon and completed between the parties. Accordingly, the gain was not taxable in assessment year 2009-10.</description>
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