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    <title>2015 (5) TMI 690 - PUNJAB &amp; HARYANA HIGH COURT</title>
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    <description>The court held that the consideration must be bifurcated and apportioned between the sale of shares and negative covenants, rejecting the argument that there was no consideration for the negative covenants. The Tribunal&#039;s order was deemed reasonable, and the apportionment towards the negative covenants was upheld. The consideration for the negative covenants was found not assessable to tax under Section 28 of the Income Tax Act. Consequently, the appeals were dismissed with no order as to costs.</description>
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      <link>https://www.taxtmi.com/caselaws?id=259816</link>
      <description>The court held that the consideration must be bifurcated and apportioned between the sale of shares and negative covenants, rejecting the argument that there was no consideration for the negative covenants. The Tribunal&#039;s order was deemed reasonable, and the apportionment towards the negative covenants was upheld. The consideration for the negative covenants was found not assessable to tax under Section 28 of the Income Tax Act. Consequently, the appeals were dismissed with no order as to costs.</description>
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