Section 54 of the Income-tax Act, 1961—Capital gain— "Date of allotment" was to be reckoned as the date for computing the holding period for the purpose of capital gains - Mere fact that possession of the flat was delivered later, does not detract from the fact that the allottee was conferred a right to hold property on issuance of an allotment letter and it was further observed, that payment of balance instalments, identification of a particular flat and delivery of possession are consequential acts that relate back to and arise from rights conferred by allotment letter, thus AO the view taken by the A.O that the period of holding of the property was to be calculated on the basis of the allotment letter that was issued to the assessee by the builder can safely be held to be a possible and a plausible view and it could not have been dislodged by the Pr. CIT in exercise of her revisional jurisdiction under Sec. 263 - YOGESH MAVJIBHAI GALA V/s PR. CIT - [2020] 183 ITD 665 (ITAT-MUMBAI)