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    <title>2024 (11) TMI 867 - ITAT HYDERABAD</title>
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    <description>Territorial jurisdiction under section 127 was held inapplicable on the facts because the notice under section 153C was issued by the officer having jurisdiction over the situs of the material and property, so the jurisdiction challenge failed. The development agreement dated 30.12.2015 was treated as a transfer because it created enforceable rights for construction and sharing of built-up area, and capital gains were held taxable in assessment year 2016-17; the assessee&#039;s contrary plea was rejected. The registered valuer&#039;s report was found unreliable for want of credible contemporaneous support, so the Assessing Officer&#039;s valuation based on guidance value was upheld and the assessee&#039;s challenge failed.</description>
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      <title>2024 (11) TMI 867 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=761881</link>
      <description>Territorial jurisdiction under section 127 was held inapplicable on the facts because the notice under section 153C was issued by the officer having jurisdiction over the situs of the material and property, so the jurisdiction challenge failed. The development agreement dated 30.12.2015 was treated as a transfer because it created enforceable rights for construction and sharing of built-up area, and capital gains were held taxable in assessment year 2016-17; the assessee&#039;s contrary plea was rejected. The registered valuer&#039;s report was found unreliable for want of credible contemporaneous support, so the Assessing Officer&#039;s valuation based on guidance value was upheld and the assessee&#039;s challenge failed.</description>
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