https://www.taxtmi.com/caselaws?id=276044 The deeming transfer provision under section 2(47)(v) applies only where the transaction satisfies section 53A of the Transfer of Property Act: a written contract for consideration, part performance by delivery of possession, and the transferee's continued willingness to perform. Where the agreement was unregistered and the transferee's conduct after the dispute showed unwillingness to complete the contract, the arrangement was not enforceable for section 53A purposes. On those facts, alleged part payment or asserted possession did not complete a transfer, and the proposed tax enhancement based on transfer could not be sustained; the additions were liable to be deleted. en-us Tue, 05 Jun 2018 00:00:00 +0530 Fri, 26 Oct 2018 06:01:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276044 The deeming transfer provision under section 2(47)(v) applies only where the transaction satisfies section 53A of the Transfer of Property Act: a written contract for consideration, part performance by delivery of possession, and the transferee's continued willingness to perform. Where the agreement was unregistered and the transferee's conduct after the dispute showed unwillingness to complete the contract, the arrangement was not enforceable for section 53A purposes. On those facts, alleged part payment or asserted possession did not complete a transfer, and the proposed tax enhancement based on transfer could not be sustained; the additions were liable to be deleted. Case-Laws Income Tax Tue, 05 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276044