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    <title>2023 (10) TMI 914 - ITAT HYDERABAD</title>
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    <description>The tribunal dismissed the appeal, affirming the lower authorities&#039; findings that the transfer of agricultural land to Smilax Corporate Services LLP was a colourable device intended to evade tax. The assessee&#039;s creation of artificial capital losses to offset gains from the sale of MAA TV shares was deemed illegitimate. The conversion of the company into an LLP to exploit Section 45(3) of the Income Tax Act was also scrutinized and found to lack genuine business purpose. The tribunal upheld that the transactions were designed to evade tax rather than conduct legitimate business activities.</description>
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    <pubDate>Fri, 22 Sep 2023 00:00:00 +0530</pubDate>
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      <title>2023 (10) TMI 914 - ITAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=444691</link>
      <description>The tribunal dismissed the appeal, affirming the lower authorities&#039; findings that the transfer of agricultural land to Smilax Corporate Services LLP was a colourable device intended to evade tax. The assessee&#039;s creation of artificial capital losses to offset gains from the sale of MAA TV shares was deemed illegitimate. The conversion of the company into an LLP to exploit Section 45(3) of the Income Tax Act was also scrutinized and found to lack genuine business purpose. The tribunal upheld that the transactions were designed to evade tax rather than conduct legitimate business activities.</description>
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      <pubDate>Fri, 22 Sep 2023 00:00:00 +0530</pubDate>
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