Proprietorship to Corporate: Section 47(xiv) Rules Out Indirect Benefits Beyond Share Allotment in Tax Transition.

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....Succession of the proprietorship business in to a corporate entity - conditions prescribed in section 47 (xiv) - in the present case, it cannot be held that he has received consideration or benefit indirectly other than by way of allotment of shares, only because higher number of shares have been allotted due to revaluation - AT....