https://www.taxtmi.com/caselaws?id=18663 The transfer of a site was treated as a transfer of absolute title acquired on execution of the sale deed, not as a separable transfer of leasehold and ownership interests for capital gains purposes. Any earlier lesser leasehold interest merged into the larger ownership estate on conveyance, so no distinct leasehold right survived for separate taxation. Although leasehold rights can be capital assets, the merger doctrine prevented their independent transfer once title vested. The resulting gain was therefore short-term capital gain, and bifurcation of consideration or cost between short-term and long-term components was not permissible. en-us Mon, 30 Oct 1995 00:00:00 +0530 Sat, 31 Oct 2009 11:51:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=18663 The transfer of a site was treated as a transfer of absolute title acquired on execution of the sale deed, not as a separable transfer of leasehold and ownership interests for capital gains purposes. Any earlier lesser leasehold interest merged into the larger ownership estate on conveyance, so no distinct leasehold right survived for separate taxation. Although leasehold rights can be capital assets, the merger doctrine prevented their independent transfer once title vested. The resulting gain was therefore short-term capital gain, and bifurcation of consideration or cost between short-term and long-term components was not permissible. Case-Laws Income Tax Mon, 30 Oct 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=18663