Permissive possession under a development agreement does not trigger capital gains transfer where it is limited to construction.

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....Permissive possession granted to a developer solely to construct flats does not amount to legal possession in part performance of a contract. Such limited entry, unlike possession involving control over property contemplated for part performance, does not constitute a transfer for capital-gains purposes. Accordingly, no long-term capital-gains charge arose from the development agreement, and the related addition was deleted.....