https://www.taxtmi.com/caselaws?id=401317 Project receipts from the real estate arrangement could not be taxed again in the assessee's hands where they had already been assessed in the holding company's hands, because the assessee had no independent right to sell the units and no separate taxable profit arose. The attempt to treat the assessee as a contractor and estimate profit at 8% of construction cost also failed, as the arrangement did not create a work-contract relationship or any contractual entitlement to contractor income. Section 45(2) was inapplicable because the godown right was not genuinely converted into stock-in-trade and no transfer by the assessee was shown. The appellate relief was sustained in full. en-us Wed, 02 Dec 2020 00:00:00 +0530 Fri, 04 Dec 2020 08:04:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=401317 Project receipts from the real estate arrangement could not be taxed again in the assessee's hands where they had already been assessed in the holding company's hands, because the assessee had no independent right to sell the units and no separate taxable profit arose. The attempt to treat the assessee as a contractor and estimate profit at 8% of construction cost also failed, as the arrangement did not create a work-contract relationship or any contractual entitlement to contractor income. Section 45(2) was inapplicable because the godown right was not genuinely converted into stock-in-trade and no transfer by the assessee was shown. The appellate relief was sustained in full. Case-Laws Income Tax Wed, 02 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=401317