S. 45(3) : Capital gains – Transfer of capital asset to firm – AOP – I Introduction of development rights by way of capital contribution- Even though a transfer but it is not a sale because there neither any receipt nor any accrual of any consideration- Provisions of section 50C of the Act could not be applied to sale development rights – When there is inconsistency in special provision and general provision – Special provision will prevail .[ S.50C ]