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    <title>2024 (7) TMI 1179 - ITAT NAGPUR</title>
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    <description>A joint development agreement that merely permits the developer to enter as a licensee for construction, while the owners retain entitlement to a defined share of the built-up area, was treated as not constituting a transfer under section 2(47)(v) in the year of execution. On that footing, capital gains were not taxable for that year, and the later recognition in section 45(5A) was noted as consistent with taxation arising on completion-related events rather than execution alone. For bank deposits, the explanation based on rental income, transfers from close relatives, and past savings was partly accepted, so only the unexplained balance was sustained.</description>
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      <description>A joint development agreement that merely permits the developer to enter as a licensee for construction, while the owners retain entitlement to a defined share of the built-up area, was treated as not constituting a transfer under section 2(47)(v) in the year of execution. On that footing, capital gains were not taxable for that year, and the later recognition in section 45(5A) was noted as consistent with taxation arising on completion-related events rather than execution alone. For bank deposits, the explanation based on rental income, transfers from close relatives, and past savings was partly accepted, so only the unexplained balance was sustained.</description>
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