No capital gains on conversion of partnership into private limited company irrespective of subsequent change in the shareholding : AAR

AAR Ruling: No capital gains are accrued or arisen at the time of conversion of partnership into a private limited company under Part IX of the Companies Act, irrespective of subsequent change in the shareholding of such company [Umicore Finance Luxembourg (AAR No. 797 of 2009)]. Facts: Umicore Finance Luxembourg (applicant), incorporated in Luxembourg, was the holding company of its wholly owned subsidiary, Anandeya Zinc Oxides Pvt. Ltd. (Anandeya), an Indian company. Anandeya was incorporated as a private limited company on 13 September 2005 under Part IX and sect6ion 565 of the Companies Ac...