Property Transfer Date for Capital Gains to be Counted from Allotment Date, Not Registration Date Under Section 2(47)

HC allowed the appeal regarding determination of property acquisition date for capital gains calculation. The court held that transfer date should be considered as allotment date (1.8.2006) rather than agreement registration date (18.3.2008). The ruling established that property rights accrued to assessee upon allotment, evidenced by initial payment made before allotment and subsequent adherence to payment schedule. HC emphasized that 'transfer' under Income Tax Act should be interpreted distinctly from Transfer of Property Act, and allotment created direct interest in property. Matter remanded to AO for reassessment considering 1.8.2006 as transfer date. .....

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