https://www.taxtmi.com/caselaws?id=16946 Section 9 read with Explanation 2 to section 2(15) of the Estate Duty Act, 1953 does not create any deemed gift, and the Act cannot be expanded by borrowing that concept from the Gift-tax Act. A transaction treated as a sale cannot have an alleged deemed gift segregated from it merely because the sale consideration is below market value. Explanation 2 to section 2(15) applies to extinguishment of rights, but it does not support the mixed sale-and-deemed-gift theory advanced by the Revenue. Accordingly, the difference between market value and sale consideration was not includible in the deceased's estate on that basis. en-us Fri, 14 Mar 1997 00:00:00 +0530 Mon, 14 Sep 2009 12:17:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16946 Section 9 read with Explanation 2 to section 2(15) of the Estate Duty Act, 1953 does not create any deemed gift, and the Act cannot be expanded by borrowing that concept from the Gift-tax Act. A transaction treated as a sale cannot have an alleged deemed gift segregated from it merely because the sale consideration is below market value. Explanation 2 to section 2(15) applies to extinguishment of rights, but it does not support the mixed sale-and-deemed-gift theory advanced by the Revenue. Accordingly, the difference between market value and sale consideration was not includible in the deceased's estate on that basis. Case-Laws Income Tax Fri, 14 Mar 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16946