Deemed consideration for partner-to-firm transfers may attract capital gains tax; genuineness of contribution affects applicability. A partner's transfer of a capital asset to a firm, AOP or BOI is taxed as capital gain with the amount recorded in the transferee's books deemed to be the full value of consideration. Where higher statutory valuation applies, stamp duty valuation can replace book value. Contributions of unlisted shares may trigger taxation in the transferee as income for valuation differences, while the partner's gain is computed on the recorded book value. The applicability of these rules depends on the commercial genuineness of the transfer.