Case Law Details
Case Name : Pricewaterhouse Coopers Private Ltd. Vs ACIT (ITAT Kolkata)
Related Assessment Year : 2009-10
Courts :
All ITAT ITAT Kolkata
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Pricewaterhouse Coopers Private Ltd. Vs ACIT (ITAT Kolkata)
The Assessing Officer relied on the judgment in the case of Pitney Bowes India Pvt. Ltd. vs. CIT (2012) 204 Taxmann 333(Del) , and ld. CIT(A) has relied on the judgments in the case of Sharp Business System v. DCIT [2011] 15 taxmann.com 144 (Delhi) and Tecumesh India (P.) Ltd. v. Addl. CIT [2010] 127 ITD 1 (Delhi) (SB) .
We find that these cases are distinguishable on facts :-
– Pitney Bowes (Supra): In this case, the taxpayer had acquired going concern on lumpsum consideration. Under the Business Transfer Agreement, there was n...
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can you explain it a little more
25. Section 28(iv) of the Act is reproduced below for reference:
“28. The following income shall be chargeable to income “Profits and gains of business or profession”, –