https://www.taxtmi.com/caselaws?id=35828 Capital gains under section 2(47) did not arise because the assessee's rights in the immovable property were neither transferred nor extinguished during the relevant year. The court treated the absence of registered sale deeds as fatal to any claim that title had passed, and held that mere agreements to sell and receipt of consideration did not complete a transfer. It also accepted the Tribunal's factual finding that no actual or constructive possession was delivered, so part performance was unavailable. Relinquishment of rights in immovable property likewise required a registered instrument, and no statutory or transactional basis for extinguishment was shown. en-us Tue, 25 Aug 1981 00:00:00 +0530 Wed, 17 Mar 2010 10:40:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35828 Capital gains under section 2(47) did not arise because the assessee's rights in the immovable property were neither transferred nor extinguished during the relevant year. The court treated the absence of registered sale deeds as fatal to any claim that title had passed, and held that mere agreements to sell and receipt of consideration did not complete a transfer. It also accepted the Tribunal's factual finding that no actual or constructive possession was delivered, so part performance was unavailable. Relinquishment of rights in immovable property likewise required a registered instrument, and no statutory or transactional basis for extinguishment was shown. Case-Laws Income Tax Tue, 25 Aug 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35828