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    <title>2014 (12) TMI 1199 - GUJARAT HIGH COURT</title>
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    <description>Conversion of a partnership firm into a company under Chapter IX of the Companies Act, 1956, without any physical distribution or conveyance of assets, was treated as a mere change in the form of the business and not a transfer for capital gains purposes. The High Court held that such a transformation did not attract capital gains tax under Section 45 of the Income-tax Act, 1961, because the partners&#039; interests were carried into the corporate structure rather than being extinguished by an actual transfer of assets. The addition made on that basis was therefore unsustainable and was deleted.</description>
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    <pubDate>Wed, 03 Dec 2014 00:00:00 +0530</pubDate>
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      <title>2014 (12) TMI 1199 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=177726</link>
      <description>Conversion of a partnership firm into a company under Chapter IX of the Companies Act, 1956, without any physical distribution or conveyance of assets, was treated as a mere change in the form of the business and not a transfer for capital gains purposes. The High Court held that such a transformation did not attract capital gains tax under Section 45 of the Income-tax Act, 1961, because the partners&#039; interests were carried into the corporate structure rather than being extinguished by an actual transfer of assets. The addition made on that basis was therefore unsustainable and was deleted.</description>
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      <pubDate>Wed, 03 Dec 2014 00:00:00 +0530</pubDate>
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