https://www.taxtmi.com/caselaws?id=796012 Compensation attributable to development rights transferred under a pre-existing Development Agreement may not accrue as taxable income to the landholder where the developer holds the exclusive commercial interest and corresponding entitlement. The note explains that legal title alone does not establish entitlement to the full compulsory-acquisition compensation when the developer funded acquisition, assumed commercial risks and received development rights under a genuine, consistently implemented agreement. Transfer of the relevant compensation is characterised as discharge of an overriding contractual obligation rather than application of the landholder's income. Taxing the same receipt in both hands would result in double taxation where the developer has offered it to tax, and consistent treatment of similarly placed entities supports deletion of the addition. en-us Mon, 27 Jul 2026 00:00:00 +0530 Thu, 30 Jul 2026 08:52:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796012 Compensation attributable to development rights transferred under a pre-existing Development Agreement may not accrue as taxable income to the landholder where the developer holds the exclusive commercial interest and corresponding entitlement. The note explains that legal title alone does not establish entitlement to the full compulsory-acquisition compensation when the developer funded acquisition, assumed commercial risks and received development rights under a genuine, consistently implemented agreement. Transfer of the relevant compensation is characterised as discharge of an overriding contractual obligation rather than application of the landholder's income. Taxing the same receipt in both hands would result in double taxation where the developer has offered it to tax, and consistent treatment of similarly placed entities supports deletion of the addition. Case-Laws Income Tax Mon, 27 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796012