Conversion of Private Limited Company to LLP , capital assets become property of assessee by succession, inheritance or devolution, cost of acquisition of assets shall be deemed to be cost for which previous owner of property had acquired same. ( ITA No. 3637/Mum/2015 & C.O No.2/Mum/2016, dt. 16.11.2018) ( AY.2010 -11)
ACIT v. Celerity Power LLP (2019) 174 ITD 433/197 TTJ 45 / 174 DTR 68 (Mum) (Trib.) ,www.itatonline.org
S. 49 : Capital gains – Previous owner – Cost of acquisition – Conversion of Private Limited Company to LLP -Capital assets become property of assessee by succession, inheritance or devolution, cost of acquisition of assets shall be deemed to be cost for which previous owner of property had acquired same. [ S. 2(42A)45 , 49(1)(iii)]