Income Tax Act Section 47(xiii) Exemption: Firm to Company Conversion Not a 'Transfer' u/s 2(47.

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....Capital gain - conversion of the firm into company - exemption u/s 47(xiii) applies only to a case of transfer by sale, but there is no authority for capital gain at all in the absence of a transfer under Part IX of the Companies Act inasmuch as such conversions do not fall within the definition of ‘transfer’ u/s 2(47). - AT....