S. 45 : Capital gains – Transfer – Development agreement – Irrevocable power of attorney – Registration of a contract is not relevant for in the case of section 2(47)(v) – Transferred 62 percent of land to a developer in exchange of 38 percent of the developed area to be constructed under an unregistered joint development agreement – transaction is liable to capital gains under section 2(47)(vi) in the year of agreement – Matter remanded for determination of cost of acquisition .[ S. 2(47)(vi) , 48, 50C, Transfer of Property Act , 1882 , S 53A ]