Income Addition Deleted: No Transfer of Income u/ss 60 and 63(b) of Income Tax Act.

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....Additions of Income of other person u/s 60 & 63(b) - transfer of income without transfer of corresponding asset by the assessee - As is evident from records, FCDs were issued by TGSPL to Serco International SARL much prior to reduction in share capital. Since, there is no generation of income there can be no question of transfer of income to any other person. - Additions deleted - AT....