TMI Blog2017 (4) TMI 1415X X X X Extracts X X X X X X X X Extracts X X X X ..... the aforementioned BTA and the premium amount of ₹ 6 crores was paid to it. ITAT in the impugned order dated 29th September, 2016 found that the entire sum of ₹ 6 crores was assessed as income in the hands of the holding company. In the circumstances, it was held by the ITAT, and in our view rightly, that the said income of ₹ 6 crores having already been taxed in the hands of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e order dated 29th September 2016 passed by the Income Tax Appellate Tribunal (ITAT) in ITA No. 5368/Del/2012 for the Assessment Year 2009-10 is that a premium of ₹ 6 crores received pursuant to a Business Transfer Agreement (BTA), whereby the Assessee transferred its business to Neila Retail Private Limited, should have been added to its income. 2. The facts are that the holding company ..... X X X X Extracts X X X X X X X X Extracts X X X X
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