CIT versus M/S. Atam Prakash And Sons (Delhi High Court)

The agreement for sale dated 24.06.1977 was substituted by the collaboration agreement dated 06.10.1981 and the agreement to sell dated 06.10.1981. There was no interest, much less, any right transferred in the property in favour of SSPL by the assessees and hence, as observed above, there was no transfer of a right in property as contemplated under Section 2 (47) of the Act. IN THE HIGH COURT OF DELHI AT NEW DELHI Judgment reserved on : 08.07.2008 Judgment delivered on : 08.08.2008 ITR Nos.250-251/1988 THE COMMISSIONER OF INCOME TAX -versus- M/S. ATAM PRAKASH and SONS J  U  D  G  M  EÂ...