https://www.taxtmi.com/caselaws?id=783082 Execution of a joint development agreement does not, by itself, create a taxable transfer under section 2(47) of the Income-tax Act, 1961 unless the arrangement also satisfies the requirements of section 53A of the Transfer of Property Act, 1882. Where no consideration is received or accrues and possession is given only for the limited purpose of development, capital gains under section 45(1) do not arise in the year of the agreement. On the facts, the Revenue failed to establish the kind of possession and consideration needed for transfer, so the addition towards long-term capital gains was unsustainable. en-us Fri, 05 Dec 2025 00:00:00 +0530 Tue, 09 Dec 2025 08:42:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783082 Execution of a joint development agreement does not, by itself, create a taxable transfer under section 2(47) of the Income-tax Act, 1961 unless the arrangement also satisfies the requirements of section 53A of the Transfer of Property Act, 1882. Where no consideration is received or accrues and possession is given only for the limited purpose of development, capital gains under section 45(1) do not arise in the year of the agreement. On the facts, the Revenue failed to establish the kind of possession and consideration needed for transfer, so the addition towards long-term capital gains was unsustainable. Case-Laws Income Tax Fri, 05 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783082