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    <title>1982 (5) TMI 96 - ITAT DELHI-A</title>
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    <description>Voluntary disclosure protection covers the disclosed amount, acquisition date and value, but does not prevent enquiry into whether assets are capital assets or stock-in-trade where their legal character was not declared. Jewellery and precious stones held as investments were long-term capital assets; book revaluation alone created no taxable income because no real income accrued or was realised. A purported conversion into stock-in-trade without genuine trading activity did not alter the capital character, so sale produced long-term capital gains rather than business income. Contribution of stock-in-trade to a firm did not attract capital gains, while contribution of capital assets could constitute a transfer, taxable only in the correct previous year.</description>
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    <pubDate>Thu, 13 May 1982 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=62971</link>
      <description>Voluntary disclosure protection covers the disclosed amount, acquisition date and value, but does not prevent enquiry into whether assets are capital assets or stock-in-trade where their legal character was not declared. Jewellery and precious stones held as investments were long-term capital assets; book revaluation alone created no taxable income because no real income accrued or was realised. A purported conversion into stock-in-trade without genuine trading activity did not alter the capital character, so sale produced long-term capital gains rather than business income. Contribution of stock-in-trade to a firm did not attract capital gains, while contribution of capital assets could constitute a transfer, taxable only in the correct previous year.</description>
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      <pubDate>Thu, 13 May 1982 00:00:00 +0530</pubDate>
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