https://www.taxtmi.com/caselaws?id=2120 Capital gains under section 45 accrue in the previous year when a transfer occurs, and section 2(47)(v) treats a transaction as a deemed transfer when the transferee is placed in effective possession and general control in part performance of the contract. On the facts, the agreement and supplemental arrangement, read together, showed that execution of the irrevocable power of attorney, together with the final licence and substantial receipt of consideration, was the decisive step conferring such control on the developer. The deemed transfer therefore arose in financial year 2006-07, and the capital gains were taxable in assessment year 2007-08. en-us Thu, 30 Aug 2007 00:00:00 +0530 Sat, 13 Sep 2025 12:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=2120 Capital gains under section 45 accrue in the previous year when a transfer occurs, and section 2(47)(v) treats a transaction as a deemed transfer when the transferee is placed in effective possession and general control in part performance of the contract. On the facts, the agreement and supplemental arrangement, read together, showed that execution of the irrevocable power of attorney, together with the final licence and substantial receipt of consideration, was the decisive step conferring such control on the developer. The deemed transfer therefore arose in financial year 2006-07, and the capital gains were taxable in assessment year 2007-08. Case-Laws Income Tax Thu, 30 Aug 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=2120