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    <description>An enforceable right arising from flat booking or allotment was treated as a capital asset, and surrender of that right amounted to a transfer by relinquishment. Because the right had been held for more than 36 months, the surplus received on cancellation was characterised as a long-term capital gain rather than income from other sources or a revenue receipt. On that basis, the consequential claim for exemption under section 54/54F had to be considered in accordance with law, and the receipt was held taxable under the capital gains head with corresponding exemption relief open for examination.</description>
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