Joint development transfer timing and firm-held rental income: effective possession fixes the capital-gains year and defeats later additions.

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....Rental receipts credited, accounted for and assessed in a registered partnership firm's hands remain taxable to the firm; partners' capital-account withdrawals do not constitute rental income or transfer ownership of the building. Under a registered joint development agreement granting the developer effective possession, dominion and authority over the property, transfer occurs on execution of the agreement rather than on later delivery of constructed area. The special capital-gains regime for joint development agreements operates prospectively and does not apply to earlier transactions. Rough, unparticularised loose sheets without independent corroboration cannot support additions for undisclosed or underreported rental income. The rental-income additions were deleted and later-year capital-gains additions were set aside.....