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    <title>2022 (1) TMI 1205 - ITAT MUMBAI</title>
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    <description>Capital gains are taxable in the year in which transfer occurs within section 2(47) of the Income-tax Act, not merely when the conveyance deed is registered. Because the agreement to sell, receipt of consideration, and delivery of possession had already occurred in the earlier year, the later-year reassessment lacked any failure to disclose material facts and was invalid. Section 50C could also not be applied in the reassessment year, as no fresh transfer took place in that year; the stamp duty valuation mechanism cannot shift taxability to a year in which the transfer was already completed and assessed. The reassessment and the corresponding addition were deleted.</description>
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