https://www.taxtmi.com/caselaws?id=185960 Section 41(2) was discussed as applying only within its limited statutory scope in a transfer of a going concern by a holding company to its wholly owned subsidiary, with Section 47 noted as relevant to the treatment of such intra-group transfers. The article states that the Court followed an earlier binding decision on both referred questions: the applicability of Section 41(2) was resolved against the assessee to the extent indicated, and the correctness of the AAC's direction to reframe the assessment was also determined in favour of the Revenue. The discussion emphasises that the issues were treated as concluded by prior precedent. en-us Mon, 11 Jun 2001 00:00:00 +0530 Sat, 03 Sep 2016 13:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=185960 Section 41(2) was discussed as applying only within its limited statutory scope in a transfer of a going concern by a holding company to its wholly owned subsidiary, with Section 47 noted as relevant to the treatment of such intra-group transfers. The article states that the Court followed an earlier binding decision on both referred questions: the applicability of Section 41(2) was resolved against the assessee to the extent indicated, and the correctness of the AAC's direction to reframe the assessment was also determined in favour of the Revenue. The discussion emphasises that the issues were treated as concluded by prior precedent. Case-Laws Income Tax Mon, 11 Jun 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=185960