“Transfer”, in the case of capital asset, shall include sale, exchange or relinquishment or extinguishment of any title to the asset, but shall not include the following matters, namely:-

(a) if the transfer of capital assets takes place by way of donation, under will, bequest or an irrevocable trust;

 (b) if the assets of the company are distributed in any way to the shareholders on the winding up of the company; and

(c) at the time of dissolution of a firm or other association of individual or if any capital asset is distributed on partition of the Hindu Undivided Family.