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    <title>2025 (2) TMI 737 - Supreme Court</title>
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    <description>An agreement to sell may be treated as a deemed conveyance under Explanation I to Article 25 of Schedule I of the Bombay Stamp Act, 1958 where the instrument itself shows that possession is transferred or agreed to be transferred before, at, or after execution without an intervening conveyance. The decisive factor is the contents of the document, not the label placed on the transaction, because stamp duty is attracted by the instrument. A recital that the purchaser was already in occupation as a tenant did not prevent the deed from being chargeable where the agreement also contemplated delivery of ownership possession on completion of sale. The instrument was therefore liable to impounding and deficit duty recovery.</description>
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