about exchange of assets

i have a agricultural land and not situated in the priscribed limit .so it is not a capital asset with sd value 20,00,000

and ,i want to start a entertainment media pvt ltd.
by running a movie theater

for that I found a buyer ,and he saying that I can give u the theater(sd value is 4 cr) to u in exchange of agricultural land

and I want to register the coming theater on companies name

and I know that

since it is the exchange of a capital asset with non capital asset ,of course it is a transfer as per it act ,

but it is not a taxable transfer

since the profit (4 cr -2000000)
is not attracted to pay capital gain tax

but that income would be regarded as gift u/s 56 so that we need to pay tax

because of that I am going to open a company and transfer theatre on that directly

and I would like to know that is there is any tax liability on me ,even though I transferd o. companies name directly

hint : at present the market value of both are same

thanks you sir ,in advance