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Sh. Sanjeev Lal Etc. Etc vs Commissioner Of Income Tax ... on 1 July, 2014

19. Upon careful consideration we find that the transfer qua the assessee has to be considered in A.Y.2006-07 when the MOU was entered for a consideration of Rs.26.25 lacs. Hence the date of MOU should be deemed to be the date of transfer in hands of the assessee. This proposition gets support from the decision of Hon'ble Apex Court in case of Sanjeev Lal vs. CIT in civil appeal No.5899-5900 vide order dated 01.07.2014. In this case the Hon'ble Apex court had expounded as under:-
Supreme Court of India Cites 6 - Cited by 96 - A R Dave - Full Document

Ito 7(1)(3), Mumbai vs Halcyon Resources & Mangement Pvt. ... on 30 November, 2016

"The assessee-company has claimed tax-free income of Rs.14,41,065/- during the previous year relevant. During the course of assessment proceedings, the assessee was asked to give reasons why the expenses attributable to the same shall not be added back to total income. The assessee-company vide para 9, pg 26 of the letter dated 17.09.2009 has offered that disallowance of Rs.6,43,856/- on account of interest and common expenses may be made in view of Rule 8D and the decision of ITO V. Daga Capital Management Pvt. Ltd. 312 ITR (AT) 1 (Mum)(SB). Accordingly, disallowance of Rs.6,43,856/- offered by the assessee company under sec. 14A is added back to total income of the assessee."
Income Tax Appellate Tribunal - Mumbai Cites 6 - Cited by 9 - Full Document
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