Set off of brought forward business loss & unabsorbed depreciation not available to ingenuine demerger

DCIT Vs Cummins Sales & Services (I) Ltd (ITAT Pune) Held that benefit of carried forward business losses and unabsorbed dep. u/s. 72A available only if the amalgamation/demerger is genuine Facts- The respondent-assessee is engaged in the business of sale and services of diesel engines, its spare parts and related equipment. ROI was filed on 23.11.2006 declaring a total income of Rs.55,44,54,789/- which was revised on 28.10.2007 at a total income of Rs.29,84,61,310/-. Against it, the assessment order was passed u/s 143(3) at the total income of Rs.49,78,29,562/- after disallowing set-off o...