https://www.taxtmi.com/caselaws?id=255627 The Court upheld the Tribunal's decision allowing the set-off of business losses by considering the date of allotment as the actual date of the scheme of amalgamation. It was found that the shares did not exist on the last day of the previous year, and beneficial interest in the shares did not arise. However, the Court disagreed with the Tribunal's decision on the computation of deduction under Section 80HHC, stating that unabsorbed business losses of earlier years should be set off in determining business profits for the deduction. The appeal was partly allowed, modifying the Tribunal's judgment accordingly. en-us Thu, 11 Dec 2014 00:00:00 +0530 Thu, 22 Jan 2015 07:08:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=255627 The Court upheld the Tribunal's decision allowing the set-off of business losses by considering the date of allotment as the actual date of the scheme of amalgamation. It was found that the shares did not exist on the last day of the previous year, and beneficial interest in the shares did not arise. However, the Court disagreed with the Tribunal's decision on the computation of deduction under Section 80HHC, stating that unabsorbed business losses of earlier years should be set off in determining business profits for the deduction. The appeal was partly allowed, modifying the Tribunal's judgment accordingly. Case-Laws Income Tax Thu, 11 Dec 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=255627