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    <title>1997 (1) TMI 116 - ITAT AHMEDABAD-B</title>
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    <description>Receipt of sale advance under a conditional agreement did not amount to a transfer under section 2(47) because possession was not handed over in the relevant year and the arrangement did not satisfy part-performance under section 53A of the Transfer of Property Act; capital gains arose only when possession was later delivered after permissions were obtained. A charitable trust&#039;s exemption under sections 11 and 12 could not be denied absent a statutory ground of forfeiture under section 13; delay in filing the return and non-filing of Form No. 10 were not, on these facts, ative, particularly where the trust was registered under section 12A, had genuine charitable objects, and had applied most of its income for those objects.</description>
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