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M/S. Surana Corporation Limited vs The Commissioner Of Income Tax on 28 August, 2018

In this regard, reliance was placed on the decisions in Sunil Siddharthbhai vs. CIT [(1985) 156 ITR 509 (SC)]; Dheer & Co., In re [(2011) 337 ITR 277 (AAR)]; Dana Corporation vs. Director of Income- tax (International Taxation), Mumbai [(2010) 321 ITR 178 (AAR)]; and 22/116 http://www.judis.nic.in T.C.A.Nos.590 & 591 of 2019 Goodyear Tire & Rubber Co., InRe [(2011) 334 ITR 69 (AAR)] which was affirmed by the High Court of Delhi in (2014) 360 ITR 159 (Delhi). Further, it is submitted that if there is no capital gain chargeable under Section 45 of the Act, there can be no income in terms of Section 2(24) of the Act. In this regard, reliance was placed on the decision in Cadell Weaving Co. P. Ltd. [(2001) 249 ITR 265 (Bom.)]
Madras High Court Cites 2 - Cited by 1 - K R Baabu - Full Document
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