https://www.taxtmi.com/caselaws?id=65727 Conversion of a proprietary business into a partnership, with induction of the proprietor's son for capital and managerial support, was held to be a commercial arrangement rather than a gratuitous transfer. The attempted gift-tax assessment on goodwill alone was unsustainable because goodwill was not established on the facts and no separate taxable gift arose. The transfer was also treated as falling within the business-purpose exemption under section 5(1)(xiv), since it had an integral connection with the carrying on and management of the business. The assessment was therefore not maintainable. en-us Thu, 14 Jun 1979 00:00:00 +0530 Wed, 25 Jan 2012 16:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65727 Conversion of a proprietary business into a partnership, with induction of the proprietor's son for capital and managerial support, was held to be a commercial arrangement rather than a gratuitous transfer. The attempted gift-tax assessment on goodwill alone was unsustainable because goodwill was not established on the facts and no separate taxable gift arose. The transfer was also treated as falling within the business-purpose exemption under section 5(1)(xiv), since it had an integral connection with the carrying on and management of the business. The assessment was therefore not maintainable. Case-Laws Income Tax Thu, 14 Jun 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65727