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    <title>2026 (4) TMI 1461 - ITAT SURAT</title>
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    <description>Section 80IA relief was treated as unavailable to an amalgamated company where the undertaking stood transferred under a scheme of amalgamation after 31.03.2007, because section 80IA(12A), read with the Finance Act, 2007 notes and Circular No. 3/2008, indicates that the benefit does not pass to the transferee in such cases. Section 80JJAA deduction was also treated as unavailable where the assessee&#039;s business resulted from amalgamation and business reorganisation, because the provision bars deduction when a business is acquired by transfer or formed by reconstruction. On both issues, the statutory restrictions prevailed over the amalgamation scheme and the deductions were disallowed.</description>
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      <title>2026 (4) TMI 1461 - ITAT SURAT</title>
      <link>https://www.taxtmi.com/caselaws?id=790392</link>
      <description>Section 80IA relief was treated as unavailable to an amalgamated company where the undertaking stood transferred under a scheme of amalgamation after 31.03.2007, because section 80IA(12A), read with the Finance Act, 2007 notes and Circular No. 3/2008, indicates that the benefit does not pass to the transferee in such cases. Section 80JJAA deduction was also treated as unavailable where the assessee&#039;s business resulted from amalgamation and business reorganisation, because the provision bars deduction when a business is acquired by transfer or formed by reconstruction. On both issues, the statutory restrictions prevailed over the amalgamation scheme and the deductions were disallowed.</description>
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