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    <title>1974 (4) TMI 23 - ALLAHABAD High Court</title>
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    <description>Transfer of business rights and goodwill on reconstitution of a sole business into partnership was not treated as a gift under the Gift-tax Act because the incoming partners contributed capital, the assessee retained a substantial share, and the arrangement was made for business continuity. On those facts, the transfer was for consideration and not without consideration, so the deeming rule for inadequate consideration in section 4(a) did not apply absent any finding of inadequacy. Section 4(c) also was not attracted because the transaction was not a mere release, surrender, forfeiture, or abandonment of property rights.</description>
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    <pubDate>Tue, 30 Apr 1974 00:00:00 +0530</pubDate>
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      <title>1974 (4) TMI 23 - ALLAHABAD High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=39756</link>
      <description>Transfer of business rights and goodwill on reconstitution of a sole business into partnership was not treated as a gift under the Gift-tax Act because the incoming partners contributed capital, the assessee retained a substantial share, and the arrangement was made for business continuity. On those facts, the transfer was for consideration and not without consideration, so the deeming rule for inadequate consideration in section 4(a) did not apply absent any finding of inadequacy. Section 4(c) also was not attracted because the transaction was not a mere release, surrender, forfeiture, or abandonment of property rights.</description>
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      <pubDate>Tue, 30 Apr 1974 00:00:00 +0530</pubDate>
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