https://www.taxtmi.com/caselaws?id=791126 An unregistered and unimplemented joint venture or share transfer arrangement did not amount to a transfer under section 2(47) of the Income-tax Act because it was not a legally enforceable contract under section 53-A of the Transfer of Property Act after the 2001 amendment. Section 2(47)(vi) also did not apply, as the transaction never materialised in substance and did not confer effective possession, consideration, or proprietary rights during the relevant year. As no real transfer and no real income arose in that year, the charging provision under section 45 and the computation mechanism under section 48 were not attracted, and the capital gains addition failed. en-us Mon, 27 Apr 2026 00:00:00 +0530 Wed, 06 May 2026 08:32:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791126 An unregistered and unimplemented joint venture or share transfer arrangement did not amount to a transfer under section 2(47) of the Income-tax Act because it was not a legally enforceable contract under section 53-A of the Transfer of Property Act after the 2001 amendment. Section 2(47)(vi) also did not apply, as the transaction never materialised in substance and did not confer effective possession, consideration, or proprietary rights during the relevant year. As no real transfer and no real income arose in that year, the charging provision under section 45 and the computation mechanism under section 48 were not attracted, and the capital gains addition failed. Case-Laws Income Tax Mon, 27 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791126