Retirement benefits for partners aren't transfers; not taxable under Income Tax Act section 2(47) or section 45.

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....Characterization of income - consideration received by the partner of a firm upon retirement from the firm - retirement benefit - any money received by the partner upon retirement from the partnership firm as his share in the assets of the partnership concern is not a consideration for transfer of his interest in the partnership to the continuing partners and there is no transfer within the meaning of section 2(47) - the charging provision as provided under section 45 of the Act would also fail - AT....