Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
Cross country pipeline classification and ITC entitlement: pipelines outside factory treated as immovable, ITC disallowed under Section 17 restriction...
ITAT held that post-01.04.2007 amalgamation triggers the statutory bar in section 80IA(12A), which excludes continuation of the deduction where an eligible undertaking is transferred under amalgamation or demerger; the amalgamated company was therefore ineligible for section 80IA relief. It also held that section 80JJAA(2)(b) denies deduction where the business is acquired by transfer or as a result of business reorganisation, and an amalgamation falls within that bar because the undertaking, assets and liabilities stand transferred to the resultant company. Both deductions were thus disallowed and the Revenue's appeal succeeded.
ITAT held that post-01.04.2007 amalgamation triggers the statutory bar in section 80IA(12A), which excludes continuation of the deduction where an eligible undertaking is transferred under amalgamation or demerger; the amalgamated company was therefore ineligible for section 80IA relief. It also held that section 80JJAA(2)(b) denies deduction where the business is acquired by transfer or as a result of business reorganisation, and an amalgamation falls within that bar because the undertaking, assets and liabilities stand transferred to the resultant company. Both deductions were thus disallowed and the Revenue's appeal succeeded.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
