Key legal question
Whether the late move-in still qualified for exemption from hand-changing tax.
Extracted holding
Yes. For undeveloped land, the two-year move-in period is a guideline; a substantial overrun can be excused where technical and project-related difficulties outside the buyer's effective control caused the delay.
Extracted reasoning
The house was an unusually large and complex project with difficult access, insufficient servicing, and technical challenges. The buyer and architect pursued the project without delay, and there was no sign of tactical postponement or contrary public interests.