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Commissioner Of Income Tax, Bangalore ... vs B. C. Srinivasa Setty, Etc. Etc on 19 February, 1981

19. Applying the above ratio to the facts of the TDRs, unlike self generated goodwill, where it is not possible to determine the date of acquisition, in the case of TDRs the date of acquisition is clearly ascertainable, which is evidenced in the form of Development Right Certificate issued by the BMC. Further in B.C. Srinvas Shetty's case, it was held that the goodwill generated in newly commenced business cannot be described as an 'asset' within the terms of section 45 of the Act. In view of the above discussion it is evident that the ratio of B.C. Srinivas Shetty is also directly not applicable to the TDRs and hence is distinguishable.
Supreme Court of India Cites 18 - Cited by 859 - R S Pathak - Full Document
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