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    <title>2025 (8) TMI 582 - ITAT PUNE</title>
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    <description>A development agreement could give rise to long-term capital gains only if the essential ingredients of transfer were established, including verified handing over of possession under section 2(47), read with section 45 and section 53A. The lower authorities had proceeded on the footing that possession was delivered, but the record required factual verification and the appellate order was non-speaking on merits. The matter was remitted to the Assessing Officer for examination of possession and related facts, and the capital-gains addition was not finally sustained.</description>
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      <description>A development agreement could give rise to long-term capital gains only if the essential ingredients of transfer were established, including verified handing over of possession under section 2(47), read with section 45 and section 53A. The lower authorities had proceeded on the footing that possession was delivered, but the record required factual verification and the appellate order was non-speaking on merits. The matter was remitted to the Assessing Officer for examination of possession and related facts, and the capital-gains addition was not finally sustained.</description>
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