<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2025 (12) TMI 1772 - SC Order</title>
    <link>https://www.taxtmi.com/caselaws?id=784232</link>
    <description>Deduction under s. 80ID was denied on the dominant issue whether the assessee&#039;s &quot;new&quot; hotel was formed by splitting up/reconstruction or by transfer of an existing business. Relying on concurrent factual findings that an old hotel had been operating in the relevant period and that the subsequent entity was essentially a renaming/continuation amounting to transfer of an existing business, the HC held the statutory conditions for s. 80ID were not satisfied; the disallowance was therefore sustained. The SC found no perversity in the concurrent findings and no ground to interfere under Art. 136, and consequently dismissed the SLP, affirming denial of the deduction.</description>
    <language>en-us</language>
    <pubDate>Thu, 16 Oct 2025 00:00:00 +0530</pubDate>
    <lastBuildDate>Wed, 31 Dec 2025 10:17:00 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=874914" rel="self" type="application/rss+xml"/>
    <item>
      <title>2025 (12) TMI 1772 - SC Order</title>
      <link>https://www.taxtmi.com/caselaws?id=784232</link>
      <description>Deduction under s. 80ID was denied on the dominant issue whether the assessee&#039;s &quot;new&quot; hotel was formed by splitting up/reconstruction or by transfer of an existing business. Relying on concurrent factual findings that an old hotel had been operating in the relevant period and that the subsequent entity was essentially a renaming/continuation amounting to transfer of an existing business, the HC held the statutory conditions for s. 80ID were not satisfied; the disallowance was therefore sustained. The SC found no perversity in the concurrent findings and no ground to interfere under Art. 136, and consequently dismissed the SLP, affirming denial of the deduction.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Thu, 16 Oct 2025 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=784232</guid>
    </item>
  </channel>
</rss>