https://www.taxtmi.com/caselaws?id=39493 Conversion of preference shares into ordinary shares under the issue terms was treated as an exchange, because section 45 read with section 2(47) includes transfer by exchange and exchange in its ordinary sense means a mutual transfer of ownership in kind rather than a transaction for money consideration. Applying that principle, the substitution of one class of shares for another was characterised as a reciprocal swap of securities. The conversion was therefore a transfer for capital gains purposes under the Income-tax Act, 1961, and the issue was answered in favour of the assessee. en-us Fri, 04 Oct 1974 00:00:00 +0530 Fri, 16 Apr 2010 17:09:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39493 Conversion of preference shares into ordinary shares under the issue terms was treated as an exchange, because section 45 read with section 2(47) includes transfer by exchange and exchange in its ordinary sense means a mutual transfer of ownership in kind rather than a transaction for money consideration. Applying that principle, the substitution of one class of shares for another was characterised as a reciprocal swap of securities. The conversion was therefore a transfer for capital gains purposes under the Income-tax Act, 1961, and the issue was answered in favour of the assessee. Case-Laws Income Tax Fri, 04 Oct 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39493