crores, the attempt to now consider the revalued
amount of such assets at Rs. 8,218 crores, amounts
to change of opinion.
(v) The primary ... consideration, taxability on account of
transfer of assets, impact of revaluation of assets
upon revaluation of the assets of the firm, even though the assets had been
revalued well before the assessee company had been inducted as partner ... figure arrived at during earlier revaluation
made on 30-09-2003 was reduced from the present revaluation.
The revaluation reserve already existing in the books
capital funds
in relation to bank's deposits or its assets is a well known and
universally accepted measure of the strength and stability ... standards, the Committee opined that the banks
should have their assets revalued on a more realistic basis and on the
basis of their realizable value
total assets" shall mean,
total assets as appearing in the balance sheet excluding the
increase on account of revaluation of assets but including ... decrease on account of revaluation of assets."
4. The AO, instead of adopting the average value of investment of
which income is not part
total assets" shall mean, total
assets as appearing in the balance sheet excluding the increase on
account of revaluation of assets but including ... decrease on account
of revaluation of assets."
14. As far as Rule 8D (2) (i) is concerned, the AO has necessarily to record
that
capital funds in relation to bank’s deposits or its assets is a well known
and universally accepted measure of the strength and stability ... standards, the Committee
opined that the banks should have their assets revalued on a more
realistic basis and on the basis of their realizable value
date of succession. In the above pretext, the Appellant Firm revalued its assets as on 30.11.1991 and the Partnership business was converted into the business ... asset as (a) no consideration was received or accrued on transfer of assets from the firm to the company; (b) the firm has only revalued
profit and loss account
(excluding the depreciation on account of revaluation of assets); or
(iib) the amount withdrawn from revaluation reserve and credited ... does not exceed the amount
of depreciation on account of revaluation of assets referred to in
clause (iia); or]
[( iii) the amount of loss brought
profit and loss account (excluding the depreciation on account of revaluation of assets); or
(iib) the amount withdrawn from revaluation reserve and credited ... does not exceed the amount of depreciation on account of revaluation of assets referred to in clause (iia); or
(iii) the amount of loss brought
profit and loss account (excluding the
depreciation on account of revaluation of assets); or
(iib) the amount withdrawn from revaluation reserve and credited ... does not exceed the amount of depreciation on account of
revaluation of assets referred to in clause (iia); or]
ITA No.1892/Kol/2012
