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    <description>Long-term capital gains were not taxable where a registered sale deed existed but possession was not effectively transferred and the agreed consideration was not fully received. The surrounding facts showed an ongoing dispute, post-dated cheques that were not honoured, and pending litigation, so the conditions associated with transfer by part performance were not satisfied. On those facts, the transaction did not amount to a completed transfer for capital gains purposes, and no real income arose on a merely notional basis.</description>
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