Transfer of land from subsidiary to holding is not covered u/s 45 hence claim of LTCG not allowable

DCIT Vs Avantha Realty Ltd (ITAT Delhi) ITAT Delhi held that in view of provision of 47(v) of the Act the transaction of transfer of land from subsidiary to holding company is not covered u/s. 45 of the Act. Accordingly, when the transaction does not falls within ambit of section 45, then any claim of long term capital loss/profit cannot be allowed. Facts- The assessee mainly contested that the CIT(A) has grossly erred in confirming the action of AO in disallowing long term capital loss of IN 3,74,14,984 in the assessment order for the relevant assessment year incurred on account of transfer o...