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    <title>2021 (9) TMI 188 - ITAT BANGALORE</title>
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    <description>Reassessment beyond four years was upheld because the assessee had not disclosed the joint development transaction in the return or computation, so the statutory condition of failure to fully and truly disclose material facts was satisfied. However, the joint development agreement did not amount to a transfer in the relevant assessment year because the arrangement had not been acted upon, no consideration was received, no building plan was sanctioned, and there was no development activity or demonstrated readiness and willingness by the developer. On those facts, the deemed transfer provision could not apply, and the capital gains addition was deleted.</description>
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      <title>2021 (9) TMI 188 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=411843</link>
      <description>Reassessment beyond four years was upheld because the assessee had not disclosed the joint development transaction in the return or computation, so the statutory condition of failure to fully and truly disclose material facts was satisfied. However, the joint development agreement did not amount to a transfer in the relevant assessment year because the arrangement had not been acted upon, no consideration was received, no building plan was sanctioned, and there was no development activity or demonstrated readiness and willingness by the developer. On those facts, the deemed transfer provision could not apply, and the capital gains addition was deleted.</description>
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      <pubDate>Wed, 01 Sep 2021 00:00:00 +0530</pubDate>
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