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    <title>2021 (8) TMI 235 - ITAT SURAT</title>
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    <description>In an unabated section 153C assessment, additions cannot survive unless they are founded on incriminating material found during search; material linked only to survey documents was insufficient, so the additions for assessment year 2011-12 were deleted. On capital gains, the transfer of land was treated as complete in assessment year 2011-12 when possession, consideration and part performance had taken effect under section 2(47) read with section 53A of the Transfer of Property Act, even though the formal sale deed was executed later. The later deed did not defer taxability, so capital gains were not chargeable in assessment year 2013-14.</description>
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