Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed income.
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....Section 56(2)(x) is described as applying only when immovable property is actually received during the relevant previous year. Execution and registration of a redevelopment agreement, without completed construction, possession, or enjoyment of permanent alternate accommodation, creates a contractual right to future accommodation rather than receipt of immovable property. Allotment of such accommodation in exchange for relinquishment of tenancy rights is characterised as a reciprocal commercial exchange, not a transfer without consideration. The discussion further states that the charging deeming fiction requires strict construction and should not be extended to this redevelopment arrangement.....
TaxTMI