Allowability of Loss on sale of shares of wholly-owned subsidiary

In the case of Apollo Tyres Ltd vs. ACIT , ITAT Cochin held that The loss on sale of shares of a wholly-owned subsidiary is allowable under Section 37(1) of Income Tax Act, 1961 as a business loss if the investment in the subsidiary was made for commercial purposes. Relevant Extract of the Judgment 22. Grounds Nos. 8 and 8.1 pertain to the disallowance of business loss of Rs. 4,07,24,151/- incurred by the assessee on the sale of its wholly own subsidiary. In the year under consideration, the appellant company has shown a loss of Rs. 4,07,24,151/- on the sale its 100% share holding in Apollo Ty...