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    <title>1965 (4) TMI 128 - PUNJAB HIGH COURT</title>
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    <description>Where an undertaking is purchased under a contractual option embedded in a licence, the transaction is treated as a sale for income-tax purposes rather than a compulsory acquisition in the ordinary sense, and the surplus over written down value is assessable under the deemed surplus provision. An additional 20 per cent payment under the licence and statutory scheme is part of the sale consideration, not separate solatium, because it forms part of the agreed price mechanism. The material also notes that the issue of loss on service lines was not pressed. The overall effect is that the amount received under the purchase arrangement is treated as taxable sale consideration.</description>
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    <pubDate>Thu, 08 Apr 1965 00:00:00 +0530</pubDate>
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      <title>1965 (4) TMI 128 - PUNJAB HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=272445</link>
      <description>Where an undertaking is purchased under a contractual option embedded in a licence, the transaction is treated as a sale for income-tax purposes rather than a compulsory acquisition in the ordinary sense, and the surplus over written down value is assessable under the deemed surplus provision. An additional 20 per cent payment under the licence and statutory scheme is part of the sale consideration, not separate solatium, because it forms part of the agreed price mechanism. The material also notes that the issue of loss on service lines was not pressed. The overall effect is that the amount received under the purchase arrangement is treated as taxable sale consideration.</description>
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      <pubDate>Thu, 08 Apr 1965 00:00:00 +0530</pubDate>
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