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    <title>2025 (10) TMI 1482 - TELANGANA HIGH COURT</title>
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    <description>Lump-sum transfer of the entire bottling undertaking as a going concern, including assets, liabilities, goodwill, distribution network and non-compete rights, constituted a slump sale where no individual values were assigned. For assessment year 1998-99, Section 50B, operative only from 1 April 2000, and Section 41(2) did not apply. The licensing arrangement was principal-to-principal, so the consideration was not agency-termination compensation under Section 28(ii)(c); later Section 28(ii)(e) was irrelevant. As the transfer extinguished the business structure and source of income, the undivided consideration retained capital-receipt character and could not be artificially apportioned or taxed under separate heads.</description>
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