Part Performance of Transaction fall within ambit of section 2(47) of IT Act

RELEVANT PARAGRAPHS: 11. Keeping in view the nature of the transaction between the Assessee and the so called Developer, coupled with the transfer and the possession of the immovable properties, we find that the transaction amounts to conveyance in favor of the purchaser of the properties and the transfer was completed on the date when the purchases were executed and possession was handed over. By means of these documents executed by the Assessee, the Assessee had transferred all material rights and interest in the property, coupled with possession in favor of the purchaser which by no means i...