Dismissing the appeal of the revenue the Tribunal held that , the provisions of S. 2(47)(v) read with S. 53A were not applicable. The settlement for cancellation of agreement took place after the close of the assessment year 2012-13. There was no contract in the eyes of law under S. 53A after 2001 unless the contract was registered and the undisputed fact was that the agreement relied upon by the Department was an unregistered agreement. Therefore the addition was liable to be deleted. ( AY.2012-13)