Capital Gains Not Applicable on AOP to Company Conversion Due to Lack of Transferor and Transferee u/s 45(1).

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....Addition on account of capital gain - conversion of AOP/trust in company - transfer of the assets u/s 2(47) - till the time of conversion, the AOP remained in existence and the moment conversion took place, the company came into existence - the AOP and company never remained in existence simultaneously - transfer of a capital asset u/s 45(1) is possible only when there is a transferor and the transferee - no capital gain....