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Property received pursuant to a family settlement was held not to constitute a 'transfer' under the definition of transfer and therefore not taxable as deemed income under the provision addressing property received without consideration. The tribunal accepted that the gift deed merely formalised title vesting between members who constituted an HUF, facts which the AO did not contest and which the CIT(A) found established. Consequence: the gift was treated as the formal execution of a family settlement, exempting it from being treated as taxable deemed income.
Property received pursuant to a family settlement was held not to constitute a 'transfer' under the definition of transfer and therefore not taxable as deemed income under the provision addressing property received without consideration. The tribunal accepted that the gift deed merely formalised title vesting between members who constituted an HUF, facts which the AO did not contest and which the CIT(A) found established. Consequence: the gift was treated as the formal execution of a family settlement, exempting it from being treated as taxable deemed income.
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