https://www.taxtmi.com/caselaws?id=766904 The ITAT Ahmedabad ruled against the assessee on the primary issue of capital gains taxation arising from demerger of treasury undertaking. The tribunal held that the demerger was non-qualifying under Section 2(19AA)(ii) as the assessee transferred assets worth Rs. 39.23 crores while retaining liabilities of Rs. 37.15 crores, violating the requirement to transfer all related liabilities. However, the tribunal ruled favorably on several other issues: deleted disallowance under Section 14A for interest expenses, allowed product registration expenses as revenue expenditure, upheld Section 80IC deduction claims for Baddi unit without profit segregation, permitted deduction on scrap sale income, and deleted provision for goods expiry as allowable expenditure based on scientific assessment. en-us Tue, 18 Feb 2025 00:00:00 +0530 Thu, 06 Mar 2025 07:35:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766904 The ITAT Ahmedabad ruled against the assessee on the primary issue of capital gains taxation arising from demerger of treasury undertaking. The tribunal held that the demerger was non-qualifying under Section 2(19AA)(ii) as the assessee transferred assets worth Rs. 39.23 crores while retaining liabilities of Rs. 37.15 crores, violating the requirement to transfer all related liabilities. However, the tribunal ruled favorably on several other issues: deleted disallowance under Section 14A for interest expenses, allowed product registration expenses as revenue expenditure, upheld Section 80IC deduction claims for Baddi unit without profit segregation, permitted deduction on scrap sale income, and deleted provision for goods expiry as allowable expenditure based on scientific assessment. Case-Laws Income Tax Tue, 18 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766904