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    <title>2023 (10) TMI 26 - ITAT INDORE</title>
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    <description>An unregistered agreement could not be used to treat a third party as the deemed owner of immovable property or to shift sale consideration away from the assessee where the registered sale deed stood in the assessee&#039;s name and the consideration was received under that deed. The analysis held that, after the 2001 registration amendments, such an agreement could not be enforced for section 53A of the Transfer of Property Act, and section 2(47) of the Income-tax Act was not the correct basis for characterising the business receipt. An enhancement for notional interest also failed because it depended entirely on the same rejected arrangement and therefore had no independent foundation.</description>
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    <pubDate>Tue, 26 Sep 2023 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=443803</link>
      <description>An unregistered agreement could not be used to treat a third party as the deemed owner of immovable property or to shift sale consideration away from the assessee where the registered sale deed stood in the assessee&#039;s name and the consideration was received under that deed. The analysis held that, after the 2001 registration amendments, such an agreement could not be enforced for section 53A of the Transfer of Property Act, and section 2(47) of the Income-tax Act was not the correct basis for characterising the business receipt. An enhancement for notional interest also failed because it depended entirely on the same rejected arrangement and therefore had no independent foundation.</description>
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      <pubDate>Tue, 26 Sep 2023 00:00:00 +0530</pubDate>
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