https://www.taxtmi.com/caselaws?id=12097 Section 2(47)(v) applies to a development agreement only where the contract, read as a whole, effectively transfers possession or complete control in part performance under section 53A of the Transfer of Property Act, 1882. Mere substantial compliance, partial permissions, or payment of a substantial part of consideration are not enough by themselves. On the stated facts, the agreement contemplated further stages and did not justify treating the transfer as complete in assessment year 1996-97 for capital gains purposes. The factual basis for the Tribunal's contrary view was also undermined by reliance on mistaken chronology and irrelevant material. en-us Thu, 13 Feb 2003 00:00:00 +0530 Tue, 12 May 2026 14:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12097 Section 2(47)(v) applies to a development agreement only where the contract, read as a whole, effectively transfers possession or complete control in part performance under section 53A of the Transfer of Property Act, 1882. Mere substantial compliance, partial permissions, or payment of a substantial part of consideration are not enough by themselves. On the stated facts, the agreement contemplated further stages and did not justify treating the transfer as complete in assessment year 1996-97 for capital gains purposes. The factual basis for the Tribunal's contrary view was also undermined by reliance on mistaken chronology and irrelevant material. Case-Laws Income Tax Thu, 13 Feb 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12097