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    <title>2026 (5) TMI 38 - ITAT HYDERABAD</title>
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    <description>Execution of a joint development agreement did not amount to a transfer for capital gains purposes where possession was handed over only for limited development activity and no consideration was received during the year. On those facts, the conditions for deeming transfer under section 2(47)(v) of the Income-tax Act, read with section 53A of the Transfer of Property Act, were not satisfied, so section 45(1) did not apply. The long-term capital gain addition was therefore deleted, and the appeal was allowed on the core chargeability issue.</description>
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      <description>Execution of a joint development agreement did not amount to a transfer for capital gains purposes where possession was handed over only for limited development activity and no consideration was received during the year. On those facts, the conditions for deeming transfer under section 2(47)(v) of the Income-tax Act, read with section 53A of the Transfer of Property Act, were not satisfied, so section 45(1) did not apply. The long-term capital gain addition was therefore deleted, and the appeal was allowed on the core chargeability issue.</description>
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