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Section 45(2) of Income Tax Act applies only after explicit conversion of capital asset into stock-in-trade by owner.

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Full Text of the Document

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....Capital gain - effective date of Conversion of capital asset into stock in trade - till the time the owner himself either converts the capital asset into stock-in-trade, the provisions of section 45(2) of the Act will not be attracted. Thus, what is provided is that only positive act/conduct of the owner assessee in applying/treating a capital asset into stock-in-trade is relevant to determine the applicability of section 45(2) of the Act. - AT....