INCOME TAX: Where assessee converted his proprietorship concern into a private limited company, in view of fact that assessee had a bona fide belief that since there was no value for self-generated goodwill in terms of section 55(2), allotment of shares for same pursuant to conversion of proprietory concern into public limited company would not be considered as transfer within meaning of section 2(47), there being a genuine difference of opinion between assessee and Assessing Officer in not allo
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