S. 45(3) not permit A.O. to substitute full value of consideration other than the amount recorded in the books of account of joint venture

ITO Vs. Chiraayu Estate & Dev. (P) Ltd. (ITAT Mumbai) The profits or gains arising from the transfer of a capital asset by a person to a firm or other association of persons or body of individuals (not being a company or a co-operative society) in which he is or becomes a partner or member, by way of capital contribution or otherwise, shall be chargeable to tax as his income of the previous year in which such transfer takes place and, for the purposes of section 48, the amount recorded in the books of account of the firm, association or body as the value of the capital asset shall be deeme...