Tribunal held that entire project land was owned by SNCML and it was merely the godown right which was assigned to the assessee-company. Further, even the cost of such godown right was assumed by SNCML in its estimated construction cost of project. The assessee had no right to sell any unit, the godown right was embedded in the cost of the units developed which were sold by SNCML. As far as section 45(2) was concerned, it related to conversion of capital asset into stock-in-trade which is to be chargeable to tax. For that, there must be a transfer u/s 2(47) of the Act. As there was no conversion in the instant case, the same could not be taxed in the hands of Assessee. (AY 2011-12)