https://www.taxtmi.com/forum/issue?id=2204 Section 47(xiiib) non-recognition applies to company-to-LLP conversions or transfers where assets and liabilities vest in the LLP, shareholders become partners with proportional capital and profit shares, no consideration other than partnership interest is received, former shareholders retain at least half aggregate profit share for five years, turnover in any of the three preceding years does not exceed the statutory threshold, and no distribution from accumulated profits is made for three years. Expert commentary links the turnover phrase to tax-audit definitions and discusses whether exempt dividend receipts form part of turnover, with an apparent contradiction regarding treatment of dividend exempt under the exemption provision. en-us Wed, 08 Sep 2010 12:23:52 +0530 Thu, 23 Jan 2025 15:58:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=2204 Section 47(xiiib) non-recognition applies to company-to-LLP conversions or transfers where assets and liabilities vest in the LLP, shareholders become partners with proportional capital and profit shares, no consideration other than partnership interest is received, former shareholders retain at least half aggregate profit share for five years, turnover in any of the three preceding years does not exceed the statutory threshold, and no distribution from accumulated profits is made for three years. Expert commentary links the turnover phrase to tax-audit definitions and discusses whether exempt dividend receipts form part of turnover, with an apparent contradiction regarding treatment of dividend exempt under the exemption provision. Discussion-Forum Income Tax Wed, 08 Sep 2010 12:23:52 +0530 https://www.taxtmi.com/forum/issue?id=2204