The assessee surrendered his profit sharing ratio to the extent of 5% share in favour of existing partners and received Rs .400 as compensation from them . The share was reduced from 30% to 25% . The assessee has the said receipt as not taxable as a capital receipt. The AO has not agreed with the submission of assessee and asseseed as revenue receipt . Order of the AO is affirmed by the CIT (A) . On appeal allowing the appeal of the assessee the Tribunal held that the compensation received by the assesssee from the existing partners on mere reduction of its share of profits in the partnership firm does not amount to any transfer u/s 2 (47) of the Act and consequently , does not give rise to capital gains . Referred CIT v. P.N.Paunwani ( 2013) 356 ITR 676 (Karn) (HC) ( ITA No. 7189/Mum/ 2014 & 5324 / Mum/2016 dt. 19 -3 2020.(AY. 2010-11 & 2012 -13 )