Assessee is  in business of real estate development. She converted her land into stock-in-trade.  Thereafter, she earmarked certain land for road and other common amenities purpose in terms of municipal regulations.  Assessee had executed a gift deed and handed over land in favour of Municipality.  Assessing Officer  held that the  assessee had relinquished her right in land earmarked for road and other common facilities which was transfer as per section 47(iii) and, thus, computed capital gains on same and made additions to income.  The  Assessing Officer also invoked section 45(2) on ground that when land was converted into stock-in-trade, assessee was liable to pay tax on business profits in year in which such land was transferred.   CIT (A) deleted the addition. On appeal the Tribunal held that the  land earmarked for public utility purpose in terms of municipal regulations while forming residential layout could not be brought to tax either under section 47(iii) or 45(2) because relinquishment of right in such land could not be considered as extinguishment of any right in property which could be considered as transfer under section 47(iii). Since the  assessee had executed a gift deed of land without any consideration, question of computing long-term capital gains on such land and also business profit in terms of section 45(2) would not arise. Order of CIT(A) deleting the addition is affirmed.  (AY. 2015-16)