The real impact of the amended provision of section 53 A of  the Transfer of Property Act on taxation of transfer  of capital assets under the circumstances referred to in clause (v )of section 2 ( 47) of the income tax Act .  
The existing provision  of section 2(47)(v) of the  income tax Act is mainly focusing on taxability of transfer of capital assets of the nature that is referred to in the old provision of section 53 A of  the Transfer of property Act , wherein it was stated that if the transferor has allowed the transferee to take over the possession of his property as part performance of the contract of nature referred therein without having proper sale document registered as per the provision stated under the Registration Act’1908,  Whereas the amended provisions of  section 53A of the Transfer of property Act   is now  emphasizing on compulsory registration of all relevant documents in support of transfer /sale of  properties  of all  nature of  contracts  including the  transfer /sale of properties of the  nature referred to in the old provision of 53A of the TP Act . The immediate question that we have in mind is that whether the transfer / sale of properties through unregistered supporting documents would be exempted from capital gain tax or not .     
 After reading out the below referred points that would highlight the existing inherent necessity of referring  the old  provisions of  section  53 A of Transfer of property Act  while drafting the income tax  provisions in  section 2 (47) (V) of the income tax Act ,  we may  come to a conclusion that the amended provisions of 53 A would not  affect the existing system of taxing the deemed transfer of any immovable properties  that  would merely result in shifting of possession of property from  transferor to transferee   without going for proper  registration immediately  .                   
It is accepted that there is  a  reference made in  clause  (v) of  section  2 ( 47) of the Income tax Act in such a manner that transactions of nature referred to in  section 53A of transfer of property will be considered as deemed transfer to levy tax on deemed transfer  but  it does not mean that capital gain tax would be levied on the deemed transfers as explained above subject to  strict compliance of the relevant provisions of the Transfer of property Act ,particularly with reference to the provisions that  now emphasizing on compulsory registration of documents in support of transfer of legal title from transferor  to transferee  . 
 The  limited purpose of application of the provisions  contained in section  53A of Transfer of property Act in the Income tax law  is to interpret the implied meaning of deemed transfer of property as explained in  the existing provision of section 2(47) (v) of Income tax Act  and not to decide about  the taxability of transfer of capital assets concerned  ,that is , the limited application of provisions of other statutes would not defeat the intended or implied  purpose build in the relevant laws  , and hence we may infer that the change in the Transfer of property Act as to compulsory registration of transfer / sale of immovable properties   to claim better title on the property concerned   would not have any direct  impact on the existing provision of income tax which aims to tax transfer of capital assets concluded either by registered documents or unregistered documents , and this fact was  impliedly  accepted by ITAT Bench  on 6th April 2013          
Now another relevant question is that whether the person having power of attorney would be considered as transferor or not  in the circumstance that one who granted or executed  power  in favor of GPA  holder  failed to meet out his obligation of paying  capital gain tax on transfer /sale of property  that  was concluded and registered by the  grantee or holder of  power  .   The answer would be based on the type of the  GPA  as explained bellow 
If an registered irrevocable and unconditional  GPA  executed in favor of power holder or grantee of power  by legal owner of the property empowering the former to act on behalf   latter  without any specific  restrictions and conditions as to conclude the end deal and make registration accordingly ,  we may infer that the legal owner of property has unconditionally allowed the power holder to take over  possession of  the property on the basis unconditional GPA and also infer that transfer of capital assets took place as per the provisions stated in section 2 (47) (v) of the Income tax Act .  Now we would think about the method of taxing  the capital gain accrued on the first deemed  transfer that  took place between the legal owner and  GPA  holder who is having irrevocable unconditional GPA  . The legal owner would be responsible for capital gain tax that to be computed on the basis of guideline value of the  property prevailed on the date of execution of GPA and this  registered irrevocable & unconditional GPA would also  be considered as implied  transfer document  to confirm  the implied  transfer /sale take place between the legal owner & GPA holder . The reason for  treating the irrevocable unconditional  GPA as transfer document in support of  the implied sale  between the  legal owner  and  GPA holder is that the legal owner is responsible to pay out  tax on transfer /sale of immovable property after considering the provisions stated in section 50C of the Income tax Act  if the actual sale  price of the property involved is less than guideline value prevailed on the date of transfer  ( in the given case of deemed transfer ,  it is date of execution of unconditional GPA ) , and in the given case the  actual price of  the property on the date of execution of this unconditional GPA would not be  ascertainable so that full guideline value would be taken as deemed consideration or sale value for the implied transfer between the legal owner & holder of unconditional  GPA  .  The actual transfer that would take place later between the   holder of unconditional GPA  and  the  buyer of the property  referred  in the  GPA  would be treated as another transfer of capital assets notwithstanding the fact that the power holder acted on behalf of legal owners of the property  and  the question of taxability of this second transfer would  be based on actual transfer price or guide line value prevailed on the date of second transfer . If there is no change between the  guideline value prevailed on the date of execution of unconditional GPA and the date of actual sale effected by holder of GPA  , the power holder will not be liable for capital gain tax  . If the  actual price of last sale concluded by GPA  holder is higher than the guideline value prevailed on date of final sale ,  GPA holder  will be responsible for capital gain tax on the differential value arrived at after deducting  the guideline value prevailed on the date of execution of GPA  from the actual sale  price  of last sale concluded by GPA holder 
If the legal owner of the property  has executed   restricted / conditional / specific / revocable power of attorney in favor of power holder , the legal owner is the only person liable for capital gain tax payable on the value of property sold or transferred  by  power holder  subject to compliance of  the provisions contained in section 50C of Income tax Act .