Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
ITAT determined the transaction as a valid slump sale under Section 2(42C). The agreement unequivocally demonstrated parties' intention to transfer entire business operations, assets, liabilities, and contracts as an inseparable whole for INR 22.40 crores lump sum consideration. Specific clauses confirmed no individual asset valuation and transaction constituted a comprehensive business transfer on an "as is where is" basis. The appellate tribunal rejected revenue's contentions, finding lower authorities incorrectly interpreted the agreement. ITAT directed the Assessing Officer to apply Section 50B and compute business income accordingly, effectively ruling in favor of the assessee.
ITAT determined the transaction as a valid slump sale under Section 2(42C). The agreement unequivocally demonstrated parties' intention to transfer entire business operations, assets, liabilities, and contracts as an inseparable whole for INR 22.40 crores lump sum consideration. Specific clauses confirmed no individual asset valuation and transaction constituted a comprehensive business transfer on an "as is where is" basis. The appellate tribunal rejected revenue's contentions, finding lower authorities incorrectly interpreted the agreement. ITAT directed the Assessing Officer to apply Section 50B and compute business income accordingly, effectively ruling in favor of the assessee.
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