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ITAT held that revaluation of partnership firm assets and subsequent admission of new partners resulting in reduced profit-sharing ratios of existing partners does not constitute a taxable transfer under section 2(47). The tribunal determined that asset revaluation preceded new partner introduction and credited amounts to partners' capital accounts in their respective ratios without effecting any transfer. Partners possess no defined share in partnership assets during firm subsistence, therefore realignment of profit-sharing ratios upon new partner admission does not constitute relinquishment of non-existent asset shares. Section 45(4) provisions regarding partnership dissolution were inapplicable. Finance Act 2021 amendments to sections 45(4) and 9B, effective from April 1, 2021, were prospective and irrelevant to assessment year 2017-18. AO's short-term capital gains addition confirmed by CIT(A) was deleted, allowing assessee's appeal.
ITAT held that revaluation of partnership firm assets and subsequent admission of new partners resulting in reduced profit-sharing ratios of existing partners does not constitute a taxable transfer under section 2(47). The tribunal determined that asset revaluation preceded new partner introduction and credited amounts to partners' capital accounts in their respective ratios without effecting any transfer. Partners possess no defined share in partnership assets during firm subsistence, therefore realignment of profit-sharing ratios upon new partner admission does not constitute relinquishment of non-existent asset shares. Section 45(4) provisions regarding partnership dissolution were inapplicable. Finance Act 2021 amendments to sections 45(4) and 9B, effective from April 1, 2021, were prospective and irrelevant to assessment year 2017-18. AO's short-term capital gains addition confirmed by CIT(A) was deleted, allowing assessee's appeal.
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