HC explains when Transfer to holding company cannot be regarded as Transfer

CIT Vs Shardlow India Ltd. (Madras High Court) In this case The assessment was reopened on 06.8.2013 by issuing a notice under Section 148 of the Act on the ground that the assessee transferred some portion of its land at Sembium to its holding company namely M/s.Simpson & Co. Ltd., for a consideration of Rs.375 lakhs resulting in a profit on sale of asset and the same was not offered to tax under the head ‘capital gains’ against the assessee on the ground that the assessee company is a 100% subsidiary of M/s. Simpson & Co. Ltd. by referring to Section 47(v) of the Act. Section 47 ...