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    <title>2020 (1) TMI 219 - ITAT AMRITSAR</title>
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    <description>Capital gains arising from a development agreement were treated as taxable only to the extent of consideration actually received in the relevant year, rather than on the full accrual basis, where the transaction did not yield complete receipt during that year. The Tribunal followed earlier coordinate bench reasoning and restricted taxation to actual receipts, with the balance becoming taxable in the year of receipt. On the penalty issue, the section 271(1)(c) penalty could not survive once the quantum addition was not sustained in the manner adopted by the Assessing Officer, so deletion of penalty was upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=390606</link>
      <description>Capital gains arising from a development agreement were treated as taxable only to the extent of consideration actually received in the relevant year, rather than on the full accrual basis, where the transaction did not yield complete receipt during that year. The Tribunal followed earlier coordinate bench reasoning and restricted taxation to actual receipts, with the balance becoming taxable in the year of receipt. On the penalty issue, the section 271(1)(c) penalty could not survive once the quantum addition was not sustained in the manner adopted by the Assessing Officer, so deletion of penalty was upheld.</description>
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