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    <title>2020 (10) TMI 706 - ITAT AMRITSAR</title>
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    <description>Seized unsigned MOUs and related agreements may support an addition for unexplained investment in land where later conduct, payment schedules, registered conveyances, and linked documents show that the transaction was actually acted upon. The tax authority may examine the real nature of the arrangement by considering surrounding circumstances and human probabilities rather than the papers in isolation. On that basis, the land transaction was treated as real and attributable to the assessee, so the subsequent sale and consideration were regarded as a taxable transfer giving rise to short-term capital gain. The note emphasises that de facto transfer and enabling enjoyment of immovable property can satisfy the statutory concept of transfer.</description>
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      <title>2020 (10) TMI 706 - ITAT AMRITSAR</title>
      <link>https://www.taxtmi.com/caselaws?id=399732</link>
      <description>Seized unsigned MOUs and related agreements may support an addition for unexplained investment in land where later conduct, payment schedules, registered conveyances, and linked documents show that the transaction was actually acted upon. The tax authority may examine the real nature of the arrangement by considering surrounding circumstances and human probabilities rather than the papers in isolation. On that basis, the land transaction was treated as real and attributable to the assessee, so the subsequent sale and consideration were regarded as a taxable transfer giving rise to short-term capital gain. The note emphasises that de facto transfer and enabling enjoyment of immovable property can satisfy the statutory concept of transfer.</description>
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