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    <title>2019 (1) TMI 1599 - ITAT AHMEDABAD</title>
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    <description>An amalgamation scheme&#039;s appointed date controls the availability of carry-forward business loss and unabsorbed depreciation under section 72A when the statutory conditions under Rule 9C are met; a separate cut-off date for objections or concessions does not displace the appointed date. On that basis, the amalgamating company&#039;s accumulated loss and depreciation were available for set-off in the year of amalgamation. The disallowance relating to sales promotion expenses also did not survive because the factual basis for the deletion was not rebutted, and the addition had already been addressed under section 154. The Revenue&#039;s appeal was therefore unsuccessful in full.</description>
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      <link>https://www.taxtmi.com/caselaws?id=282201</link>
      <description>An amalgamation scheme&#039;s appointed date controls the availability of carry-forward business loss and unabsorbed depreciation under section 72A when the statutory conditions under Rule 9C are met; a separate cut-off date for objections or concessions does not displace the appointed date. On that basis, the amalgamating company&#039;s accumulated loss and depreciation were available for set-off in the year of amalgamation. The disallowance relating to sales promotion expenses also did not survive because the factual basis for the deletion was not rebutted, and the addition had already been addressed under section 154. The Revenue&#039;s appeal was therefore unsuccessful in full.</description>
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