https://www.taxtmi.com/caselaws?id=769070 ITAT Cochin held that for distribution of capital assets upon firm dissolution, section 45(4) applies using fair market value as consideration. The matter was remitted to AO to compute capital gains under section 45(4) using Rs. 7.4 crores as sale consideration after reducing WDV. The tribunal clarified that sections 45 and 48 must be read together for capital gains computation. Importantly, provisions of section 45(4) and section 50 cannot be applied simultaneously to the same amount, as section 50 specifically addresses depreciable assets while section 45(4) governs asset distribution scenarios. Revenue's appeal was partly allowed. en-us Fri, 21 Mar 2025 00:00:00 +0530 Fri, 18 Apr 2025 08:38:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769070 ITAT Cochin held that for distribution of capital assets upon firm dissolution, section 45(4) applies using fair market value as consideration. The matter was remitted to AO to compute capital gains under section 45(4) using Rs. 7.4 crores as sale consideration after reducing WDV. The tribunal clarified that sections 45 and 48 must be read together for capital gains computation. Importantly, provisions of section 45(4) and section 50 cannot be applied simultaneously to the same amount, as section 50 specifically addresses depreciable assets while section 45(4) governs asset distribution scenarios. Revenue's appeal was partly allowed. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769070