Development Agreement Isn't a Property Sale; No Capital Gains Tax Due to Section 53(A) of Transfer of Property Act.

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....LTCG - since the agreement was a Development Agreement, there was no transfer of property by way of sale and even the ingredients of “Part Performance” as per Sec.53(A) of the Transfer of Property Act cannot be said to have been attracted, so as to attract the provisions of Capital Gains tax - AT....