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    <description>Receipt for grant of development rights under a redevelopment agreement was characterised as consideration for transfer of a capital asset, because development rights form part of the bundle of rights in immovable property. The residuary head of income could not be invoked where the receipt was directly referable to the specific head of Capital Gains, and the payer&#039;s accounting treatment did not change the recipient&#039;s tax character. The receipt was therefore taxable under Capital Gains, not Income from Other Sources, and exemption under section 54EC was to be allowed in accordance with law.</description>
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