“date of transfer”

Capital GainsSection 2(47)Section 2(47)965 judgments

The decision most relied on for date of transfer is CIT v. Balbir Singh Maini (398 ITR 531), cited in 228 judgments on BharatTax.

Leading authorities on date of transfer

CIT v. Balbir Singh Maini

398 ITR 531 · 2017 · Supreme Court

228

citing judgments

A transfer of immovable property, for the purpose of capital gains under section 2(47)(v) of the Income-tax Act, occurs only when the agreement allowing possession in part performance of a contract is a registered instrument, as mandated by Section 53A of the Transfer of Property Act.

Chaturbhuj Dwarkadas Kapadia v. CIT

260 ITR 491 · 2003 · High Court

150

citing judgments

For capital gains purposes, a 'transfer' under section 2(47)(v) occurs and capital gains arise in the year when possession of the property is handed over in part performance of a contract, such as a joint development agreement. This was the settled position before the specific provisions of section 45(5A) were introduced.

Sanjeev Lal v. CIT

365 ITR 389 · 2014 · Supreme Court

122

citing judgments

For claiming capital gains exemption under beneficial provisions like section 54, the 'date of transfer' can be the date of the agreement to sell, particularly when coupled with substantial advance consideration or an enforceable right, adopting a purposive and liberal interpretation to acknowledge the assessee's intent.

Suraj Lamp & Industries (P) Ltd. v. State of Haryana

340 ITR 1 · 2012 · Supreme Court

citing judgments

A transfer of immovable property by way of sale is legally valid only through a duly stamped and registered deed of conveyance. Unregistered instruments like agreements to sell, General Power of Attorney, or wills do not transfer title or create an interest in the property.

CIT v. T.K. Dayalu

202 Taxmann 531 · 2011 · High Court

citing judgments

In a Joint Development Agreement (JDA), capital gains arise for chargeability to tax when the complete control over the property is passed to the developer, with the date of such transfer of control being relevant for determining the assessment year. This includes considerations of possession under Section 53A of the Transfer of Property Act.

PCIT v. Swananda Properties (P.) Ltd.

111 Taxmann.com 94 · 2019 · High Court

citing judgments

Prior to the incorporation of the proviso to section 43CA(1) with effect from 1st April 2019, section 43CA did not envisage any limit regarding the difference between the stamp duty value and the actual sale consideration received by the assessee for the transfer of immovable property that was stock-in-trade.

CIT v. Ashaland Corporation

133 ITR 55 · 1982 · High Court

citing judgments

Income from the sale of immovable property, including any 'on-money' component, is taxable only when the sale is complete, marked by the execution and registration of the sale deed and/or transfer of possession to the buyer.

CIT v. R.L. Sood

245 ITR 727 · 2000 · High Court

citing judgments

Exemption under Section 54 for capital gains on a residential property is available even if the sale deed is not registered within the stipulated time, provided a substantial amount of consideration is paid, or the delay in completion/registration is beyond the assessee's control.

Judgments citing date of transfer

Income Tax Officer, Ward- 1(1), Guntur vs. Potti Kumara Naga Venkata Sai Chakravarthy, Guntur

In the result, appeals ITA

ITA 368/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR

Section 132Section 132(4)Section 147Section 148

conclusion of the Assessing Officer in assessment for assessment year 2001-02 is that he refers to the assessee's submission regarding the date of transfer being on 12-4-2000 when the broker raised the bill dated 12-4-2000 after scheduled pay- in/pay-out of securities to Stock Exchange

Income Tax Officer, Guntur vs. Madhusushana Venkata Subba Rao Potti, Guntur

In the result, appeals ITA

ITA 367/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR

Section 132Section 132(4)Section 147Section 148

Assistant Commissioner of Income Tax, Guntur vs. Ms.Vijayasai Lakshmi Srinivasa Cotton Mills, Guntur

In the result, appeals ITA

ITA 359/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Respondent: Shri Badicala Yadagiri, CIT-DR

Section 132Section 132(4)Section 147Section 148

Maruti Suzuki India Ltd., New Delhi vs. DCIT, New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 901/DEL/2017[2012-13]Status: DisposedITAT Delhi08 Oct 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’: NEW DELHI BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI VIMAL KUMAR

M/S Maruti Suzuki India Ltd., New Delhi vs. DCIT, New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and

ITA 287/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 35Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’: NEW DELHI BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI VIMAL KUMAR

DCIT, New Delhi vs. M/S. Maruti Suzuki India Ltd., New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 1024/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’: NEW DELHI BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI VIMAL KUMAR

Saurashtra Gramin Bank Manager (F & A), Rajkot vs. The Pr. Commissioner of Income Tax-I, Rajkot

In the result, the appeal filed by the assessee is allowed

ITA 37/RJT/2022[2017-18]Status: DisposedITAT Rajkot30 Sept 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 37/Rjt/2022 (Assessment Year: 2017-18) (Hybrid Hearing) Saurashtra Gramin Bank Vs. The Pr. Cit-1, Manager (F & A), Rajkot 1St Floor Wing 2, Lic Jeevan Prakash Building, Tagore Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahas2116H (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Ms. A.D. Vyas, ARFor Respondent: Shri Sanjay Punglia, CIT-DR

Section 143(3)Section 14ASection 263Section 36(1)(viii)Section 37(1)

Transfer of scrips from one category to another, under all circumstances, should be done at the acquisition cost/book value/market value on the date of transfer, whichever is the least, and the depreciation, if any, on such transfer should be fully provided for. v. Transfer of scrips from AFS / HFT category ... book value, the provision against depreciation held against this security (including the additional provision, if any, required based on valuation done on the date of transfer) should be adjusted to reduce the book value to the market value and the security should be transferred at the market value

Addl.CIT, Special Range-5, New Delhi vs. Jitf Waterways Ltd., New Delhi

The appeal of the Revenue is dismissed

ITA 546/DEL/2019[2015-16]Status: DisposedITAT Delhi30 Sept 2025AY 2015-16

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)

For Appellant: Shri Saksham Singhal, AdvocateFor Respondent: Ms Monika Singh, CIT-DR

Section 139(5)Section 143(3)Section 37

vessel and the ld.CIT(A) has held that the carrying value of 6 vessels in the books of the subsidiary on the date of transfer, i.e., 29.09.2014 shall be the actual cost in the hands of the assessee. Accordingly, he directed that the excess amount be reduced from actual cost ... business. It is undisputed that carrying value of the vessels in the hands of JITF Shipping & Logistics Pte Ltd. (transferor) as on the date of transfer, i.e., 29.09.2014 was USD 1,35,46,018/- which is substantiated by the audited financial statements of the transferor and that amount should

Ideaforge Technology Ltd, Mahape vs. ACIT, Circle 15(2)(1), Mumbai

The appeal of the assessee is allowed

ITA 867/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Sept 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhriआयकर अपील सं./Ita No. 867/Mum/2025 (निर्धारण वर्ा / Assessment Year: 2017-18) Ideaforge Technology V/S. Assistant Commissioner Ltd. बिधम Of Income Tax, Circle El-146, Ttc Industrial 15(2)(1), Mumbai Area, Electronic Zone, Room No. 357, 3Rd Floor, Midc, Mahape, Navi Aayakar Bhavan, Maharshi Mumbai Karve Road, Mumbai 400020 स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No: Aabci6495B Appellant/अपीलधथी .. Respondent/प्रनिवधदी निर्धाररिी की ओर से /Assessee By: Shri Subodh Ratnaparkhi Shri. Leyaqat Ali Aafaqui (Sr Dr) रधजस्व की ओर से /Revenue By: सुिवधई की िधरीख / Date Of Hearing 22.08.2025 घोर्णध की िधरीख/Date Of Pronouncement 26.09.2025 आदेश / O R D E R Per Renu Jauhri [A.M.] :- This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 11.12.2024, Passed U/S. 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “Act”] For Assessment Year [A.Y.] 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal: “On The Facts & In Law, 1. The Hon. Cit(A) Erred In Upholding The Action Of The Id Ao In Making Addition Of Rs. 6,60,02,100/- By Relying Upon The Provisions Of Section 56(2)(Viib) Of The It Act, 1961 On The Ground That The Consideration Received By The Appellant For Issue Of P A G E | 2

For Appellant: Shri Subodh Ratnaparkhi

Section 143(3)Section 250Section 56(2)(viIb)Section 56(2)(viib)

amount set apart for payment of dividends on preference shares and equity shares where such dividends have not been declared before the date of transfer at a general body meeting of the company; (iii)reserves and surplus, by whatever name called, even if the resulting figure is negative, other than ... amount set apart for payment of dividends on preference shares and equity shares where such dividends have not been declared before the date of transfer at a general body meeting of the company; (iii) reserves and surplus, by whatever name called, even if the resulting figure is negative, other than

Smt . Rajani Surendra Adamane, Nagpur vs. Income Tax Officer Ward 6(1), Nagpur

In the result, Assessee’s appeal is allowed in the aforesaid terms

ITA 103/NAG/2020[2011-12]Status: DisposedITAT Nagpur25 Sept 2025AY 2011-12

Bench: Shri Narender Kumar Choudhrysmt. Rajani Surendra Ito, Ward-4(4), Nagpur Adamane, Plot No.30, Near Ghodke School Surendra Vs. Nagar, Hudkeshwar Road, Nagpur-440024. Pan: Alapa 9897 L (Appellant) (Respondent)

For Appellant: Shri Bhavesh Moryani, Ld. AdvFor Respondent: Shri Surjit Kumar Saha, Ld. Sr.D.R

Section 250Section 50CSection 54(2)Section 54F

according to the provisions of section 54 of the Act, the Assessee is entitled to purchase a house within 02 years on the date of transfer took place of the purchased property, or to construct a residential house within a period of 03 years after such date of sale

Tata Communications Limited, Mumbai vs. Principle Commissioner of Income Tax, Mumbai

In the result, the question of law referred to the Special Bench is answered in favour of the assessee

ITA 3515/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Sept 2025AY 2018-19

Bench: Shri Saktijit Dey & Shri Arun Khodpiatata Communications Limited Pr. Cit, Videsh Sanchar Bhavan, Mumbai-1 Vs. M. G. Road, Fort, Mumbai-400 001 Pan/Gir No. Aaacv 2808 C (Appellant) : (Respondent) Appellant By : Shri J. D. Mistri Respondent By : Shri Ritesh Misra, Cit Dr Date Of Hearing : 25.09.2025 Date Of Pronouncement : 25.09.2025 O R D E R Per Saktijit Dey: The Present Appeal, At The Instance Of The Assessee, Assails Order Dated 21.03.2025, Passed U/S. 263 Of The Income Tax Act, 1961 (‘The Act’ For Short), By Learned Principal Commissioner Of Income Tax (‘Ld. Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2018-19. 2. Though The Assessee Has Raised Multiple Grounds, Both On Jurisdictional Issues As Well As On Merits, However, There Is Consensus Between The Parties That The Appeal Can Be Decided On Merits, In Which Event, There Is No Need To Go Into Various Other Issues Raised In Appeal.

For Appellant: Shri J. D. MistriFor Respondent: Shri Ritesh Misra, CIT DR

Section 112Section 143(3)Section 263Section 50

long term capital asset. If the long term capital asset has been held for more than 36 months immediately preceding the date of transfer, then transfer of such long term capital asset has to be taxed at the rate of profit under the Act. In the present case

Pravanshu Samantaray, Cuttack vs. The Income Tax Officer, Ward-1(1), Cuttack

In the result, appeal of the assesee is allowed

ITA 369/CTK/2025[2018-19]Status: DisposedITAT Cuttack24 Sept 2025AY 2018-19

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.369/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2018-2019) Pravanshu Samantaray, Vs Ito, Ward-1(1), Cuttack C/O : Adikanda Samantaray, At: Rajabagicha,Po Telenga Bazar Dist : Cuttack-753009 Pan No. : Acxps 7565 D (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Sr. Dr राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 24/09/2025 घोषणा की तारीख/Date Of Pronouncement : 24/09/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of Ld.Cit(A), National Faceless Appeal Centre(Nfac), Delhi, Dated 29/04/2025, For The Assessment Year 2018-2019. 2. It Was Submitted By The Ld. Ar That The Assesee Owned One Residential House Representing A Flat In Bhubaneswar Where The Assesee Is Staying. The Assesee Is Also Deriving Rental Income From A Commercial Property Jointly Owned By The Assesee & His Brothers & Sisters. It Was The Submission That The Commercial Property Was Received By The Assesee On The Demise Of His Father. It Was The Submission That The Said Commercial Property Was A Joint Owned Property With The Brothers & Sisters Of The Assesee. It Was The Submission That The Assesee Also Owned

For Appellant: Shri P.K.Mishra, Sr. DRFor Respondent: Shri Vijay Singh, Sr. DR

Section 4Section 54ASection 54F

clearly shows that the assesee should not own more than one residential house other than the new assets on the date of transfer of the original asset. The words used is “residential house”, admittedly, the property at Janpath, Bhubaneswar is not a residential house but is a commercial property. Therefore

Paras and Shubham Chaudhary Legal Heir of Kanhaiya Lal, Panchkula vs. ITO, Ward 2, Panchkula

In the result, appeal of the assessee is allowed

ITA 1236/CHANDI/2016[2007-08]Status: HeardITAT Chandigarh24 Sept 2025AY 2007-08

Bench: Shri Rajpal Yadav & Shri Krinwant Sahay

For Appellant: Shri Rishab Gupta & Shri Mukesh Aggarwal,CAsFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR

Section 10(37)Section 18Section 28Section 4Section 5

capital gains are not income accruing from day to day. It is deemed income which arises at a fixed point of time, viz, date of transfer. Section 45(5), newly inserted by the Finance Act, 1987, w.e.f. 1.4.88 and subsequently amended, retrospectively w.e.f. 1.4.88, by the Finance Act, 1991, enacts ... clause (iii) of clause (14) of section 2; (ii)such land, during the period of two years immediately preceding the date of transfer, was being used for agricultural purposes by such Hindu undivided family or individual or a parent of his; (iii)such transfer is by way of compulsory acquisition

Next Estate & Projects Private Limited, Mumbai vs. DCIT, Central Circle 5(1), Mumbai

In the result, the appeal filed by the assessee is hereby partly allowed for statistical purpose

ITA 460/MUM/2024[2014-15]Status: DisposedITAT Mumbai24 Sept 2025AY 2014-15

Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), MS. KAVITHA RAJAGOPAL (Judicial Member)

For Appellant: Shri K. Gopal, Adv. Shri OmFor Respondent: Shri Leyaqat Ali Aafaqui, SR DR

Section 133(6)Section 143(3)Section 250Section 43C

immovable property is to be taken into consideration for the purpose of determining the stamp duty value of the said property when the date of transfer is on a subsequent date. 14. Both the lower authorities have not disputed the date of receipt of the advance payment received ... valuation as on the date of the receipt of the part consideration received by the assessee has to be considered and not the date of transfer even in the absence of the written agreement, for the reason that the proviso only emphasizes that consideration or part consideration has been received

Jyoti Jain, New Delhi vs. DCIT, Circle-19(2), New Delhi

In the result, ground no. 5 of appeal is allowed for statistical purpose

ITA 4983/DEL/2018[2014-15]Status: DisposedITAT Delhi23 Sept 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं.4983/िद"ी/2018 (िन.व. 2014-15) Jyoti Jain, 25/94, Shakti Nagar, New Delhi 110007 ...... अपीलाथ"/Appellant Pan No: Adipj-0775-G बनाम Vs. Deputy Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle 19(2), New Delhi

For Appellant: Shri Nirbhay Mehta & Ms. Vanshika Mehta, AdvocatesFor Respondent: Shri Om Prakash, Sr. DR

Section 54F

available only where the assessee does not own more than one residential house other than the new asset on the date of transfer of original asset. It is assessee’s own admission that the assessee owns residential house comprising of ground floor, first floor and second floor. Each floor

Syedali Ebrahim, Thiruvananthapuram vs. ITO Ward-1(1), Thiruvananthapuram

ITA 571/COCH/2025[2017-18]Status: DisposedITAT Cochin22 Sept 2025AY 2017-18

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Padmanathan K. VFor Respondent: Smt. Leena Lal

Section 133(6)Section 143(3)Section 250Section 68

represent any fresh capital introduction but is a result of internal transfer entries from existing accounts duly recorded and verifiable: Ledger Account Date of transfer Amount H. Loan A/c. 31-03-2016 Rs.93,31,065.00 14407300002160 Syed Ali Ebrahim 19-08-2015 Rs.3,75,000.00 Syed Ali Ebrahim

Aadinath Gems & Jewellers P.Ltd, Mumbai vs. ITO 5(1)(1), Mumbai

In the result, appeal of the assessee is allowed in part for statistical purposes

ITA 3121/MUM/2015[2010-11]Status: DisposedITAT Mumbai22 Sept 2025AY 2010-11

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri K. Gopal and Ms. Neha Paranjpe, A/RsFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. A/R

Section 133(6)Section 68

assessment order and in the case of each investor, the AO observed that the party has deposited cash either on the date of transfer to the assessee or earlier. This led to the AO to question the genuineness of the transactions and the capacity of the investors. 7. Before

Sneh Gupta, New Delhi vs. ACIT, Circle-32(1), Delhi

In the result, the appeal filed by the assessee is allowed on both counts on merit as well as jurisdictional issue raised by the assessee in the additional ground of appeal

ITA 3928/DEL/2024[2016-17]Status: DisposedITAT Delhi22 Sept 2025AY 2016-17

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shri Manoj Kumar, CIT DR

Section 143(2)Section 54F

before or two years after the transfer of original asset or construction of a property within a period of three years from the date of transfer of original asset. The AO observed that assessee has sold the shares on 17.12.2012 while the assessee has purchased a new asset ... becomes taxable 9 as income in the current assessment year that is a period of three years from the date of transfer of original asset under the provisions of section 45 of the Act. A notice was issued to the assessee why the above deduction should not be charged

DCIT Cen Cir 1(4), Mumbai vs. Grasim Industries Ltd, Mumbai

In the result, appeal of the revenue and the assessee are partly allowed, and the additional ground of the assessee is dismissed

ITA 4069/MUM/2016[2010-11]Status: DisposedITAT Mumbai09 Sept 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri J.D. Mistry – Sr. Advocate &For Respondent: Shri Arun Kanti Datta - CIT DR

Section 143(3)Section 250Section 260ASection 43BSection 45Section 801ASection 801A(4)

been fixed, therefore, net worth of the unit should be taken as on date of the framework agreement i.e. 30.06.2008 and not the date of transfer i.e. 22.05.2009." 14. The Appellant craves leave to add, to amend and/or to alter any of the grounds of appeal, if need ... raised by the revenue is dismissed. In relation to Ground No.13: Networth to be computed as on the date of Framework Agreement or Date of Transfer. 45. For the purpose of completeness, this ground is dealt with in the assessee’s appeal underneath while discussing ground no. 6. I.T.A.NO. 2897/MUM/2016

Grasim Industries Limited, Mumbai vs. DCIT, CC-1(4), Mumbai

In the result, appeal of the revenue and the assessee are partly allowed,

ITA 2897/MUM/2016[2010-11]Status: DisposedITAT Mumbai09 Sept 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri J.D. Mistry – Sr. Advocate &For Respondent: Shri Arun Kanti Datta - CIT DR

Section 143(3)Section 250Section 260ASection 43BSection 45Section 801ASection 801A(4)

been fixed, therefore, net worth of the unit should be taken as on date of the framework agreement i.e. 30.06.2008 and not the date of transfer i.e. 22.05.2009." 14. The Appellant craves leave to add, to amend and/or to alter any of the grounds of appeal, if need ... raised by the revenue is dismissed. In relation to Ground No.13: Networth to be computed as on the date of Framework Agreement or Date of Transfer. 45. For the purpose of completeness, this ground is dealt with in the assessee's appeal underneath while discussing ground no. 6. I.T.A.NO. 2897/MUM/2016