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2012 (4) TMI 402 - AT - Income TaxInvoking the provisions of section 50B to sale of assets of the M Seal Division of the Appellant - assessee contented that it was an itemized sale - Slump sale – Held that:- A close analysis of the agreement and the deeds entered into by the appellant with PIL confirms that the business as a whole was sold and not an itemized sale of assets - Directors' report and Auditors' report also talk about 'sale of business' - the business of Sealants and Adhesives of assessee includes all the processes from manufacturing to marketing and as per the ‘Agreement to Grant’ Appellant had agreed to sell/transfer and assign all rights, benefits, titles, interests of any nature in relation thereto 'business of Sealants and Adhesives', thus leading to sale of entire business – as a result of the nine agreements/ deeds entered with PIL business of Sealants and Adhesives carried out by the Appellant had gone to PIL irrevocably - agreements/deeds entered in to by both the parties prove that they are part of the one transaction only and to considered as ‘ slump sale' – against assessee.
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