M/S. Demag Delval Indl Turbomachinery ... vs The Acit 15(1), Mumbai on 16 September, 2020
purchasing of a industrial unit from other company is altogether a different
commercial decision in total contrast of the process of amalgamation
between the two companies. These are two different situation of commercial
happening which are incomparable in substance operational in two different
fields. Therefore. I am in total consonance with the view of the AO that the
ratio of the decision of CIT v. Bombay Dyeing Mfg. cannot be made applicable
in this case.