https://www.taxtmi.com/caselaws?id=19719 A final Tribunal finding that an application under section 154 was maintainable could not be reopened through reference, because the proposed question no longer arose from the impugned order. Section 53A of the Transfer of Property Act was treated as a doctrine of part performance giving defensive protection to a transferee in possession, not as an independent transfer of title. The later amendment to section 2(47) treating certain section 53A transactions as transfers was prospective, so it did not apply to the relevant assessment year. On that basis, the agreement to sell and possession arrangement were not a transfer under the unamended provision. en-us Fri, 25 Mar 1994 00:00:00 +0530 Mon, 09 Nov 2009 11:57:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19719 A final Tribunal finding that an application under section 154 was maintainable could not be reopened through reference, because the proposed question no longer arose from the impugned order. Section 53A of the Transfer of Property Act was treated as a doctrine of part performance giving defensive protection to a transferee in possession, not as an independent transfer of title. The later amendment to section 2(47) treating certain section 53A transactions as transfers was prospective, so it did not apply to the relevant assessment year. On that basis, the agreement to sell and possession arrangement were not a transfer under the unamended provision. Case-Laws Income Tax Fri, 25 Mar 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19719