https://www.taxtmi.com/caselaws?id=24237 Conversion of a sole proprietary business into a partnership with family members did not amount to a gift where the incoming partners undertook binding obligations to devote attention, and in one case full time, to the business. Those obligations constituted real consideration, so the arrangement could not be treated as a gratuitous transfer for estate duty purposes. Because the partnership deed was executed more than two years before death, section 9 of the Estate Duty Act, 1953 did not apply. On the facts found, there being no gift, section 10 also did not arise. The reference was answered in favour of the accountable persons and the proposed estate duty inclusion failed. en-us Mon, 19 Sep 1988 00:00:00 +0530 Mon, 18 Jan 2010 16:50:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24237 Conversion of a sole proprietary business into a partnership with family members did not amount to a gift where the incoming partners undertook binding obligations to devote attention, and in one case full time, to the business. Those obligations constituted real consideration, so the arrangement could not be treated as a gratuitous transfer for estate duty purposes. Because the partnership deed was executed more than two years before death, section 9 of the Estate Duty Act, 1953 did not apply. On the facts found, there being no gift, section 10 also did not arise. The reference was answered in favour of the accountable persons and the proposed estate duty inclusion failed. Case-Laws Income Tax Mon, 19 Sep 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24237