https://www.taxtmi.com/caselaws?id=26278 Entitlement to relief under section 84 of the Income-tax Act was not answered on the merits because the reference was treated as academic. The Court noted that the disqualification in section 84(2), read with the corresponding provision in section 15C of the 1922 Act, had to be tested at the time of formation of the undertaking. As the Tribunal had already found that the leasehold premises value was insignificant relative to total assets and below the statutory threshold in the Explanation, no further useful determination was required. The reference was therefore declined without pronouncing on the tax question. en-us Fri, 20 Sep 1985 00:00:00 +0530 Wed, 03 Feb 2010 18:31:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=26278 Entitlement to relief under section 84 of the Income-tax Act was not answered on the merits because the reference was treated as academic. The Court noted that the disqualification in section 84(2), read with the corresponding provision in section 15C of the 1922 Act, had to be tested at the time of formation of the undertaking. As the Tribunal had already found that the leasehold premises value was insignificant relative to total assets and below the statutory threshold in the Explanation, no further useful determination was required. The reference was therefore declined without pronouncing on the tax question. Case-Laws Income Tax Fri, 20 Sep 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=26278