CIT (Appeals) Rules Section 47(xiii)(b) Applies to Firms, Not Partners, in Conversion to Companies Case.

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....Short Term Capital Gain - conversion of the Partnership Firms into Companies - Additions in the hands of partners - CIT (Appeals) correctly deleted the additions on account of capital gain made in the hands of the Partners as he was of the opinion that the applicability of section 47(xiii)(b) at the time of conversion of the Partnership Firms into Companies can be considered only in the hands of the Partnership Firms to which the land belongs. - AT....