entry of Trend Micro India into the India Purchase
Agreement and the consummation of the transactions contemplated herein and therein, and in
consideration
Section 263 of the Act. The purchase
transaction culminated and stood consummated during the year under
review. Therefore, the cause of action did exist
loose paper itself signifies a very
presence of other parties in the consummation of sale transaction together with
land owners( KPP etc.) and purchasers
business income in the year of conversion
regardless of actual consummation. The aforesaid clause is however
applicable prospectively w.e.f. 2019-20 and seeks
held that the AO is not correct in working out differences of consummation
of power and fuel merely as per his chart which was prepared
Closing Date all necessary corporate approvals, resolutions and
authorizations necessary to consummate the settlement contemplated in this
Agreement.
3. On Closing Date, CCIL shad
investment
in the aforesaid property albeit at a smaller figure. Thus, the
consummation of undisclosed income cannot be doubted. It is only the
quantum
attached to such an
agreement which is stated to have not been consummated for variety
of reasons in the course of business. We thus
been
produced as to whether the said transfer of lands was consummated. Ld.
CIT(A) has noted that even after two years of the claim ... absence of any evidence as to whether the lands sale was consummated,
the theory that the certain persons advanced cash on various dates in
anticipation
