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    <title>1990 (11) TMI 180 - ITAT BOMBAY-A</title>
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    <description>A partnership reconstitution did not amount to a taxable gift where the assessee&#039;s reduced profit share was matched by a corresponding reduction in its capital contribution and the incoming minors brought substantial capital from independent sources. The transaction was materially different from cases involving a transfer of rights without consideration, and there was no reliable nexus between capital withdrawn by the assessee and capital contributed by the minors. On those facts, the arrangement could not be characterised as a gift, so exemption under section 5(1)(xiv) did not arise.</description>
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    <pubDate>Thu, 29 Nov 1990 00:00:00 +0530</pubDate>
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      <title>1990 (11) TMI 180 - ITAT BOMBAY-A</title>
      <link>https://www.taxtmi.com/caselaws?id=58000</link>
      <description>A partnership reconstitution did not amount to a taxable gift where the assessee&#039;s reduced profit share was matched by a corresponding reduction in its capital contribution and the incoming minors brought substantial capital from independent sources. The transaction was materially different from cases involving a transfer of rights without consideration, and there was no reliable nexus between capital withdrawn by the assessee and capital contributed by the minors. On those facts, the arrangement could not be characterised as a gift, so exemption under section 5(1)(xiv) did not arise.</description>
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      <pubDate>Thu, 29 Nov 1990 00:00:00 +0530</pubDate>
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