undertaken for that purpose, including the apportionment of and devolution of assets and
liabilities, etc. Section 394 (2) provided as follows:
"(2) Where ... purpose of devolution of assets and
liabilities:
"394....(4) In this section
(a) property includes property, rights and powers of every description and liabilities
section 49(1)(iii)(a) i.e. by succession, inheritance or
devolution. This has resulted in an apparent, patent, glaring and
obvious mistake ... Jaipur
The ld. CIT(A) after dealing with his co-terminus powers as that of the
AO by quoting the Allahabad Bench decision gave
Yogesh Das, Jaipur vs Ito, Jaipur on 31 August, 2022
vk;dj vihyh; vf/kdj
Alok Mukherjee, Individual, Jaipur vs Department Of Income Tax on 21 October, 2015
vk;dj
St. Wilfred Educational Society, ... vs Principal Commissioner Of Income Tax ... on 18 March, 2019
vk
Moinoddin S/O Rahimuddin, Ajmer vs Ito, Ajmer on 22 May, 2017
vk;dj vihyh
firm is not less than fifty per cent of the total voting power in
the company and their shareholding continues to be as such ... Under a gift or will;
(iii) (a) by succession, inheritance or devolution, or
(b) on any distribution of assets on the dissolution of a firm
