Company Succession Without Member or Asset Change: Revaluation Not Taxable as Real Profit Under Current Tax Laws.

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....Capital gains - Firm is succeeded by a company with no change either in the number of members or in the value of assets - Transfer by way of distribution of assets - the amount of revaluation of the land and building which was credited to the current accounts of the partners which was treated as loans to new companies - valuation of the assessee at market value, which was higher than the cost, resulted in the imaginary or notional potential profit out of itself and not any real profit or income which can be taxed. - HC....