https://www.taxtmi.com/caselaws?id=18043 A subsisting partnership firm's allotment of assets to partners is treated as a transfer of property, not a mere internal adjustment of capital, because the partners' common interest in the assets is replaced by exclusive ownership in the allottee. The analysis also states that a partnership firm falls within the inclusive meaning of "person" for gift-tax purposes under the Gift-tax Act, 1958. Where such transfer is made for consideration below market value, the excess of market value over the amount debited to the partners' accounts is treated as a deemed gift and taxed in the hands of the firm. en-us Thu, 27 Jun 1996 00:00:00 +0530 Sat, 26 Sep 2009 13:44:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=18043 A subsisting partnership firm's allotment of assets to partners is treated as a transfer of property, not a mere internal adjustment of capital, because the partners' common interest in the assets is replaced by exclusive ownership in the allottee. The analysis also states that a partnership firm falls within the inclusive meaning of "person" for gift-tax purposes under the Gift-tax Act, 1958. Where such transfer is made for consideration below market value, the excess of market value over the amount debited to the partners' accounts is treated as a deemed gift and taxed in the hands of the firm. Case-Laws Income Tax Thu, 27 Jun 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=18043