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    <title>2026 (3) TMI 1479 - ITAT DELHI</title>
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    <description>Section 54 exemption may extend beyond a registered sale deed where the assessee has substantially paid consideration and taken possession in part performance; the provision is treated as beneficial and the term &quot;purchase&quot; is given a wider, purposive meaning. On the facts, the vendor&#039;s title objection did not defeat the claim because the conveyance deed and mutation record showed regularisation of title at the relevant time, so the exemption was allowed. Material already on record before the Assessing Officer could not be treated as additional evidence, so rule 46A was not attracted and no remand report was required.</description>
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    <pubDate>Fri, 13 Mar 2026 00:00:00 +0530</pubDate>
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      <title>2026 (3) TMI 1479 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=788724</link>
      <description>Section 54 exemption may extend beyond a registered sale deed where the assessee has substantially paid consideration and taken possession in part performance; the provision is treated as beneficial and the term &quot;purchase&quot; is given a wider, purposive meaning. On the facts, the vendor&#039;s title objection did not defeat the claim because the conveyance deed and mutation record showed regularisation of title at the relevant time, so the exemption was allowed. Material already on record before the Assessing Officer could not be treated as additional evidence, so rule 46A was not attracted and no remand report was required.</description>
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      <pubDate>Fri, 13 Mar 2026 00:00:00 +0530</pubDate>
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