https://www.taxtmi.com/caselaws?id=25450 The Court held that the contribution of plots by the assessee to a partnership did not constitute a "transfer" under section 2(47) of the Income-tax Act, 1961, making the capital gain not taxable for the assessment year 1964-65. Relying on the Supreme Court decision in Sunil Siddharthbhai v. CIT [1985] 156 ITR 509, the Court determined that although the contribution qualified as a transfer, it did not attract capital gains tax due to the nature of the consideration involving future profits and losses of the firm. As a result, the Court ruled in favor of the assessee on both issues, concluding that capital gain was not applicable, and the penalty re-computation was not justified. en-us Mon, 23 Mar 1987 00:00:00 +0530 Thu, 28 Jan 2010 16:17:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25450 The Court held that the contribution of plots by the assessee to a partnership did not constitute a "transfer" under section 2(47) of the Income-tax Act, 1961, making the capital gain not taxable for the assessment year 1964-65. Relying on the Supreme Court decision in Sunil Siddharthbhai v. CIT [1985] 156 ITR 509, the Court determined that although the contribution qualified as a transfer, it did not attract capital gains tax due to the nature of the consideration involving future profits and losses of the firm. As a result, the Court ruled in favor of the assessee on both issues, concluding that capital gain was not applicable, and the penalty re-computation was not justified. Case-Laws Income Tax Mon, 23 Mar 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25450