Land Transfer to Firm as Capital Contribution Not Capital Asset Transfer Under IT Act Section 2(47), No Capital Gain Section 45.

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....Transfer of property u/s 2(47) or not - capital gain u/s 45 - The land was transferred by the partners to the firm as capital contribution which was recorded as stock-in-trade in the books of the firm. As such there was no transfer of capital assessee as stock-in-trade in the books of the assessee.....