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Tax Publishers
Claim under section 35DD of amalgamation expenses
- first year how reckoned
Facts:
Assessee claimed amalgamation expenses arising out of a
court approved merger on 01-12-2006 as appointed date but wef 01-04-2005.
Accordingly they claimed 2/5th of the amalgamation expense under section 35DD
for Fy 2005-06 and Fy 2006-07 of which 1/5th was rejected by lower authorities.
On appeal to ITAT alternate plea by assessee was if Fy 2006-07 was held the
first year of claim under section 35DD then 1/5th expense ought to be allowed
for Fy 2010-11.
Held in favour of the assessee that first year of claim under
section 35DD will be Fy 2006-07 thus they be allowed 1/5th expense for Fy
2010-11 as well.
Case: United
Spirits Ltd. v. Jt. CIT 2024 TaxPub(DT) 35 (Mum-Trib)
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