https://www.taxtmi.com/caselaws?id=762311 Under a Joint Development Agreement, taxable income does not arise merely on execution or stamp valuation; it arises only when the arrangement is actually implemented and the contemplated rights are fructified, so no revenue accrued in the relevant year on these facts. The deeming fiction for transfer in part performance was inapplicable where the land was treated as stock-in-trade and no actual transfer or realization had occurred, making the addition unsustainable. Reliance on a later registered cancellation deed did not breach Rule 46A where the appellate authority acted within co-terminus powers, used the document to confirm non-implementation, and no prejudice was shown. en-us Wed, 16 Oct 2024 00:00:00 +0530 Fri, 29 Nov 2024 08:16:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762311 Under a Joint Development Agreement, taxable income does not arise merely on execution or stamp valuation; it arises only when the arrangement is actually implemented and the contemplated rights are fructified, so no revenue accrued in the relevant year on these facts. The deeming fiction for transfer in part performance was inapplicable where the land was treated as stock-in-trade and no actual transfer or realization had occurred, making the addition unsustainable. Reliance on a later registered cancellation deed did not breach Rule 46A where the appellate authority acted within co-terminus powers, used the document to confirm non-implementation, and no prejudice was shown. Case-Laws Income Tax Wed, 16 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762311