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      <description>Transfer of stock exchange membership for less than market value was treated as transfer of property capable of attracting deemed gift-tax on the undervalued portion, because the membership card was regarded as an asset transferable for consideration. The same shortfall, however, could not be taxed again under the Income-tax Act after being brought to tax as a deemed gift. Capital gains were confined to the actual consideration received, not the amount already subjected to gift-tax, thereby preventing double taxation of the same difference.</description>
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