Transfer under joint development agreements requires enforceable, irrevocable divestment of property rights before capital gains can arise.

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....Transfer under a joint development agreement requires more than execution of development documents and an irrevocable power of attorney: property rights must be effectively and irrevocably parted with through an enforceable arrangement. The notes state that a later partition decree and development agreement may show that no completed transfer or real income accrued. They further explain that agricultural income from inherited land should not be rejected solely for missing old cultivation records where later records support agricultural use, the land's character is undisputed, and prior assessments accepted the claim without changed facts. A search-based addition founded only on another person's statement and ad hoc allocation requires corroborative material linking undisclosed income to the assessee.....