ITAT Pune Upholds Non-Applicability of Section 2(47) for Delayed Possession

ITO Vs Kapurba and Company (ITAT Pune) Introduction: The case of ITO vs. Kapurba and Company, decided by ITAT Pune, involves an appeal against the order passed by the Commissioner of Income Tax (Appeals)-7, Pune for the assessment year 2012-13. The central issue pertains to the applicability of Section 2(47) of the Income Tax Act. Detailed Analysis: Kapurba and Company, a firm engaged in land purchase and sale, filed its return of income declaring a total income of Rs. 10,16,327. The case was selected for scrutiny, with the Assessing Officer (AO) concluding that the firm had transferred its ca...