https://www.taxtmi.com/caselaws?id=62195 Transfer of a partner's personal immovable property to a partnership firm as capital contribution was held not to attract deemed-gift treatment under section 4(1)(a) of the Gift-tax Act because the consideration received on admission into partnership could not be precisely quantified at that stage, making any test of inadequacy inapplicable. The Revenue also could not sustain the levy by alleging a sham or tax-avoidance device, since no such factual finding was recorded in the lower orders and a fresh factual case could not be introduced at the appellate stage. The gift-tax levy was therefore unsustainable. en-us Fri, 31 Aug 1990 00:00:00 +0530 Tue, 18 Jan 2011 14:41:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=62195 Transfer of a partner's personal immovable property to a partnership firm as capital contribution was held not to attract deemed-gift treatment under section 4(1)(a) of the Gift-tax Act because the consideration received on admission into partnership could not be precisely quantified at that stage, making any test of inadequacy inapplicable. The Revenue also could not sustain the levy by alleging a sham or tax-avoidance device, since no such factual finding was recorded in the lower orders and a fresh factual case could not be introduced at the appellate stage. The gift-tax levy was therefore unsustainable. Case-Laws Income Tax Fri, 31 Aug 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=62195