Capital Gain on Registration of property bought 20years ago.

Hi, In 2000 at Noida, a Commercial property was bought through an unregistered sale agreement, jointly in two names A & B and a Power of Attorney was executed and Registered at the same time jointly in names of C & D.

Today A & B wants the Power of Attorney C & D to register the sale in their name through a Transfer from the NOIDA authority. Apparently, NOIDA authority recently started a policy to transfer commercial property only to single person, partnership or LLP or a Pvt Ltd Company.

Today, If  one is forced to create a PARTNERSHIP FIRM between A & B,  in order to register the Transfer/Conveyance deed to follow the NOIDA Authorities guidelines, would this document registration attract Capital Gain Tax. How would one resolve this, since there is no transaction between the parties involved?

Is there any other way of dealing this issue?

Thanks for your time in advance.