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    <title>2023 (6) TMI 1028 - ITAT PUNE</title>
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    <description>Sale of project property was treated as conditional on receipt of full consideration where the deed deferred possession and preserved limited development rights, so registration alone did not fix transfer for tax purposes and the gains were not taxable in that year. Alleged on-money receipt was not established because third-party search material, a pen drive and an uncorroborated statement did not independently prove payment to the assessee; the addition was deleted. A limited scrutiny challenge also failed because the disputed issues fell within the stated scope and no absence of approval for widening scrutiny was shown; reliance on third-party material in regular assessment was not invalid for want of section 153C jurisdiction.</description>
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      <title>2023 (6) TMI 1028 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=439454</link>
      <description>Sale of project property was treated as conditional on receipt of full consideration where the deed deferred possession and preserved limited development rights, so registration alone did not fix transfer for tax purposes and the gains were not taxable in that year. Alleged on-money receipt was not established because third-party search material, a pen drive and an uncorroborated statement did not independently prove payment to the assessee; the addition was deleted. A limited scrutiny challenge also failed because the disputed issues fell within the stated scope and no absence of approval for widening scrutiny was shown; reliance on third-party material in regular assessment was not invalid for want of section 153C jurisdiction.</description>
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