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Slump Sale to Subsidiary Exempt from Transfer Tax u/s 47(iv); CIT Revision u/s 263 Challenged.

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....Revision u/s 263 by CIT - slum sale - The assessee has transferred the whole business under slump sale basis and it is fact on record that it is transferred the business on going concern basis to its own subsidiary company. The transaction is covered u/s 47(iv) of the Act and accordingly it is not transfer within the provisions of the Act. - when the receipt or profit earned by the assessee are in the nature of capital receipt or capital profit, these profit has to excluded from the book profit for the purpose of section 115JB also - AT....

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Slump Sale to Subsidiary Exempt from Transfer Tax u/s 47(iv); CIT Revision u/s 263 Challenged.