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    <title>No transfer u/s 2(47) on the date of sales agreement; capital gains taxable only in year of full consideration receipt</title>
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    <description>ITAT held that no &quot;transfer&quot; of capital asset occurred in AY 2015-16 under the sale agreements for three office properties, as only 5-13% of the agreed consideration was received and contractual conditions for transfer, including full payment and handing over of documents/possession, were not fulfilled. Buyers&#039; confirmations corroborated non-payment of full consideration and non-delivery of possession. The Tribunal further accepted that capital gains were correctly offered and assessed in AY 2018-19 when full consideration was received, and the Revenue could not tax the same transaction twice. Accordingly, the addition for capital gains in AY 2015-16 was deleted and the assessee&#039;s appeal was allowed.</description>
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    <pubDate>Mon, 15 Dec 2025 08:39:22 +0530</pubDate>
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      <title>No transfer u/s 2(47) on the date of sales agreement; capital gains taxable only in year of full consideration receipt</title>
      <link>https://www.taxtmi.com/highlights?id=95050</link>
      <description>ITAT held that no &quot;transfer&quot; of capital asset occurred in AY 2015-16 under the sale agreements for three office properties, as only 5-13% of the agreed consideration was received and contractual conditions for transfer, including full payment and handing over of documents/possession, were not fulfilled. Buyers&#039; confirmations corroborated non-payment of full consideration and non-delivery of possession. The Tribunal further accepted that capital gains were correctly offered and assessed in AY 2018-19 when full consideration was received, and the Revenue could not tax the same transaction twice. Accordingly, the addition for capital gains in AY 2015-16 was deleted and the assessee&#039;s appeal was allowed.</description>
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      <pubDate>Mon, 15 Dec 2025 08:39:22 +0530</pubDate>
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