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“slump sale”

Capital GainsSection 50BSection 50B409 judgments

COROMANDEL INTERNATIONAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(2), HYDERABAD

In the result the appeal of the assessee is partly allowed for statistical purposes

ITA 738/HYD/2025[2015-2016]Status: DisposedITAT Hyderabad18 Mar 2026AY 2015-2016

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.738/Hyd/2025 ("नधा"रणवष"/ Assessment Year:2015-16) Coromandel International Vs. Dcit, Limited, Circle-2(2), Hyderabad. Hyderabad. Pan: Aaacc7852K (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Sp Chidambaram, Advocate Assessee Represented By राज"वका""त"न"ध"व/ : Ms. U. Mini Chandran, Cit-Dr Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 02/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 18/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Coromandel International Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 24/02/2025 For The Assessment Year (“A.Y.”) 2015-16. Page 1 Of 17 Coromandel International Limited Vs. Dcit 2. The Assessee Has Raised The Following Grounds Of Appeal:

Section 250Section 32Section 32(1)(ii)Section 35

however, that the amount of such reduction does not exceed the written down value as so increased; and [(C) in the case of a slump sale, decrease by the actual cost of the asset falling within that block as reduced— (a) by the amount of depreciation actually allowed

M/S. BANK OF AMERICAN , N.A,MUMBAI vs. THE JT DIT (I.T)3, MUMBAI

In the result, the appeal by the assessee is partly allowed

ITA 4154/MUM/2004[2000-2001]Status: DisposedITAT Mumbai18 Mar 2026AY 2000-2001
For Appellant: Shri Percy PardiwalaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 10Section 10(15)Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)(viia)Section 37(1)Section 44C

section\n50B of the Act are not applicable to the sale transaction, on the basis that the\nsale transaction is in the nature of “Slump Sale”. The AO, by referring to the\nvarious covenants of the agreement entered into between the assessee and\nM/s. ABN Amro Bank N.V. held that ... million also strikes down the assessee's claim that the sale of its\nRetail Banking Business is not in the nature of a Slump Sale. Accordingly,\nthe AO held that the sale transaction is in the nature of a Slump Sale and the\nprovisions of section

THE DY DIT (I.T) 1(1), MUMBAI vs. M/S. BANK OF AMERICA N.A., MUMBAI

In the result, the appeal by the assessee is partly allowed

ITA 4090/MUM/2004[2000-2001]Status: DisposedITAT Mumbai18 Mar 2026AY 2000-2001
For Appellant: Shri Percy PardiwalaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 10Section 10(15)Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)(viia)Section 37(1)Section 44C

section\n50B of the Act are not applicable to the sale transaction, on the basis that the\nsale transaction is in the nature of “Slump Sale”. The AO, by referring to the\nvarious covenants of the agreement entered into between the assessee and\nM/s. ABN Amro Bank N.V. held that ... million also strikes down the assessee's claim that the sale of its\nRetail Banking Business is not in the nature of a Slump Sale. Accordingly,\nthe AO held that the sale transaction is in the nature of a Slump Sale and the\nprovisions of section

ASCENTECH ENGINEERING SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 1686/HYD/2025[2017-18]Status: HeardITAT Hyderabad06 Mar 2026AY 2017-18
For Appellant: MS Sree Lekha, AdvocateFor Respondent: Sri Mathivanan S A, Sr. AR
Section 56(2)(vii)Section 56(2)(viib)

issue in dispute\nand perused the material on record. We find that computation of LTCG\non the transfer of undertaking as the slump sale consists of two\ncomponents. First component is sale consideration and the second\ncomponent is the net worth or cost of acquisition. When the net worth ... division is subtracted from the sale consideration, which results into\nLTCG on the slump sale. In the case of the assessee, the AO has taken\nFMV at Rs. 7,20,32,509/- which was worked out by the valuer following\nthe PECV method, whereas the assessee has followed average value

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BENGALURU vs. MANIPAL EDUCATION AND MEDICAL GROUP INDIA PRIVATE LIMITED, BENGALURU

ITA 2148/BANG/2025[2018-19]Status: DisposedITAT Bangalore25 Feb 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2018-19 M/S. Manipal Education & Medical Vs. The Assistant Commissioner Group India Pvt. Ltd., Of Income Tax, No.24/1, 15Th Floor, Jw Marriott, Vittal Central Circle – 1(2), Mallya Road, Bengaluru. Bengaluru – 560 001. Pan: Aadcm 8103 A Appellant Respondent Assessment Year: 2018-19

For Appellant: Shri. S. K. Tulsiyan, AdvocateFor Respondent: Shri. Subramanian, JCIT(DR)(ITAT), Bengaluru
Section 10Section 10(35)Section 143(3)Section 14A

Rs.75,84,440/- and addition of Rs 4,44,80,000/- on the basis of Form No 26 QB in slump sale was made, on challenge the disallowance u/s 14A was confirmed and addition of Rs 4,44,80,000 was deleted . 2. Coming to the appeal of the assessee ... facts shows that as per form No. 26 QB the assessee has shown value of the immovable property under a slump sale of ₹ 1,031,780,000/- however the sale consideration reported by the assessee is only ₹ 987,300,000 in the return of income filed for the impugned assessment

MANIPAL EDUCATION AND MEDICAL GROUP INDIA PRIVATE LIMITED ,BENGALURU vs. ACIT, CENTRAL CIRCLE-1(2), BANGALORE

ITA 2010/BANG/2025[2018-19]Status: DisposedITAT Bangalore25 Feb 2026AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2018-19 M/S. Manipal Education & Medical Vs. The Assistant Commissioner Group India Pvt. Ltd., Of Income Tax, No.24/1, 15Th Floor, Jw Marriott, Vittal Central Circle – 1(2), Mallya Road, Bengaluru. Bengaluru – 560 001. Pan: Aadcm 8103 A Appellant Respondent Assessment Year: 2018-19

For Appellant: Shri. S. K. Tulsiyan, AdvocateFor Respondent: Shri. Subramanian, JCIT(DR)(ITAT), Bengaluru
Section 10Section 10(35)Section 143(3)Section 14A

Rs.75,84,440/- and addition of Rs 4,44,80,000/- on the basis of Form No 26 QB in slump sale was made, on challenge the disallowance u/s 14A was confirmed and addition of Rs 4,44,80,000 was deleted . 2. Coming to the appeal of the assessee ... facts shows that as per form No. 26 QB the assessee has shown value of the immovable property under a slump sale of ₹ 1,031,780,000/- however the sale consideration reported by the assessee is only ₹ 987,300,000 in the return of income filed for the impugned assessment

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the three appeals of the Assessee\nare partly allowed

ITA 2149/HYD/2025[2018-19]Status: DisposedITAT Hyderabad11 Feb 2026AY 2018-19
For Appellant: \nCA MV Prasad AndFor Respondent: \nMS U Mini Chandran, CIT-DR
Section 56(2)(viib)

nissue in dispute and perused the material on record.\nWe find that computation of LTCG on the transfer of\nundertaking as the slump sale consists of two\ncomponents. First component is sale consideration\nand the second component is the net worth or cost of\nacquisition. When the net worth ... division is\nsubtracted from the sale consideration, which results\ninto LTCG on the slump sale. In the case of the\nassessee, the AO has taken FMV at Rs. 7,20,32,509/-\nwhich was worked out by the valuer following the\nPECV method, whereas the assessee has followed\naverage value

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

ITA 2148/HYD/2025[2017-18]Status: DisposedITAT Hyderabad11 Feb 2026AY 2017-18
For Appellant: \nCA MV Prasad AndFor Respondent: \nMS U Mini Chandran, CIT-DR
Section 56(2)(viib)

nissue in dispute and perused the material on record.\nWe find that computation of LTCG on the transfer of\nundertaking as the slump sale consists of two\ncomponents. First component is sale consideration\nand the second component is the net worth or cost of\nacquisition. When the net worth ... division is\nsubtracted from the sale consideration, which results\ninto LTCG on the slump sale. In the case of the\nassessee, the AO has taken FMV at Rs. 7,20,32,509/-\nwhich was worked out by the valuer following the\nPECV method, whereas the assessee has followed\naverage value

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

ITA 2147/HYD/2025[2016-17]Status: DisposedITAT Hyderabad11 Feb 2026AY 2016-17
For Appellant: CA MV Prasad AndFor Respondent: MS U Mini Chandran, CIT-DR
Section 56(2)(viib)

nissue in dispute and perused the material on record.\nWe find that computation of LTCG on the transfer of\nundertaking as the slump sale consists of two\ncomponents. First component is sale consideration\nand the second component is the net worth or cost of\nacquisition. When the net worth ... division is\nsubtracted from the sale consideration, which results\ninto LTCG on the slump sale. In the case of the\nassessee, the AO has taken FMV at Rs. 7,20,32,509/-\nwhich was worked out by the valuer following the\nPECV method, whereas the assessee has followed\naverage value

AMMANN INDIA PRIVATE LIMITED,MEHSANA vs. THE PR. CIT-3, AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1536/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad05 Feb 2026AY 2020-21

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2020-21

Section 143(3)Section 144BSection 263

Asphalt Plant business from Gujarat Apollo Industries Limited ("GAIL") and the Sensor Paver business from Apollo Earth Movers Limited ("AEML") on a slump sale basis, and in questioning the resulting goodwill arising from such genuine business transactions. 2.2 On the facts and in the circumstances of the case

TRENT LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 2(3)(1), MUMBAI

In the result, the appeal filed by the assessee is allowed

ITA 5165/MUM/2025[2018-19]Status: DisposedITAT Mumbai05 Feb 2026AY 2018-19
Section 115JSection 142(1)Section 143(3)Section 144BSection 2(11)Section 250Section 32Section 32(1)Section 32(1)(ii)

assessee acquired the 'value fashion' business segment from its group company, namely Trent Hypermarket Private Limited, with effect from 01.10.2017 by way of a slump sale for a lump sum consideration of Rs. 87.82 crores. As part of the said transaction, all assets, both tangible and intangible, and the liabilities ... pertaining to the said business segment were transferred to the assessee company.\n4. The assessee claimed depreciation on goodwill acquired as part of the slump sale and added the same to the block of intangible assets during the year. The Assessing Officer required the assessee to justify the allowability

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

ITA 294/BANG/2025[2021-22]Status: DisposedITAT Bangalore30 Jan 2026AY 2021-22
For Appellant: \nShri Padamchand Kincha, CAFor Respondent: \nShri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

306/Mum/2019, and other judicial precedents, the\nlearned CIT(A) held that the sixth proviso to section 32 applies to cases\nof business acquisition through slump sale or business transfer\nagreement.\n26.2 The proviso mandates that depreciation allowable to the\nsuccessor cannot exceed the depreciation that would have been\nallowable

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 293/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Jan 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

306/Mum/2019, and other judicial precedents, the learned CIT(A) held that the sixth proviso to section 32 applies to cases of business acquisition through slump sale or business transfer agreement. 26.2 The proviso mandates that depreciation allowable to the successor cannot exceed the depreciation that would have been ITA Nos.290

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 292/BANG/2025[2019-20]Status: DisposedITAT Bangalore30 Jan 2026AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

306/Mum/2019, and other judicial precedents, the learned CIT(A) held that the sixth proviso to section 32 applies to cases of business acquisition through slump sale or business transfer agreement. 26.2 The proviso mandates that depreciation allowable to the successor cannot exceed the depreciation that would have been ITA Nos.290

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

ITA 291/BANG/2025[2018-19]Status: DisposedITAT Bangalore30 Jan 2026AY 2018-19
For Appellant: \nShri Padamchand Kincha, CAFor Respondent: \nShri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

306/Mum/2019, and other judicial precedents, the\nlearned CIT(A) held that the sixth proviso to section 32 applies to cases\nof business acquisition through slump sale or business transfer\nagreement.\n26.2\nThe proviso mandates that depreciation allowable to the\nsuccessor cannot exceed the depreciation that would have been\nallowable

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 290/BANG/2025[2017-18]Status: DisposedITAT Bangalore30 Jan 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

306/Mum/2019, and other judicial precedents, the learned CIT(A) held that the sixth proviso to section 32 applies to cases of business acquisition through slump sale or business transfer agreement. 26.2 The proviso mandates that depreciation allowable to the successor cannot exceed the depreciation that would have been ITA Nos.290

KOVALAM RESORT PRIVATE LIMITED ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX 2(1)(1), MUMBAI

In the result, the appeal of the assessee for Assessment Year

ITA 6580/MUM/2025[2012-13]Status: DisposedITAT Mumbai30 Jan 2026AY 2012-13

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokar1. Ita No. 6580/Mum/2025 (Assessment Year: 2012-13) 2. Ita No. 6578/Mum/2025 (Assessment Year: 2013-14) & 3. Ita No. 6579/Mum/2025 (Assessment Year: 2014-15) Kovalam Resort Private Dcit 2(1)(1), Limited 561, Aayakar The Leela, Sahar, Andheri Vs. Bhavan, M. K. East, Mumbai-400 059 Road, Mumbai- 400 020 Pan/Gir No. Aaeck4804H (Applicant) (Respondent) Assessee By Shri Dharan Gandi & Shri Ravi Gupta, Ld. Ars Revenue By Shri Ritesh Misra, Ld. Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 30.01.2026

Section 115JSection 142(1)Section 143(1)Section 143(2)Section 143(3)

Kovalam Leela Raviz Hotel”. The assessee acquired the hotel undertaking of M/s Hotel Leela Venture Ltd. on a going concern basis by way of slump sale under a Scheme of Arrangement sanctioned by the Hon’ble Bombay High Court under sections 391 to 394 of the Companies Act, 1956, vide ... During the course of assessment proceedings, it was noticed that the assessee had acquired Hotel Leela, Kovalam as a going concern under slump sale from M/s Hotel Leela Ventures Ltd. The assessee claimed depreciation aggregating to Rs. 25,86,15,073/- on the assets so acquired. The Assessing Officer then

KOVALAM RESORT PRIVATE LIMTIED ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX 2(1)(1), MUMBAI

In the result, the appeal of the assessee for Assessment Year

ITA 6579/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jan 2026AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokar1. Ita No. 6580/Mum/2025 (Assessment Year: 2012-13) 2. Ita No. 6578/Mum/2025 (Assessment Year: 2013-14) & 3. Ita No. 6579/Mum/2025 (Assessment Year: 2014-15) Kovalam Resort Private Dcit 2(1)(1), Limited 561, Aayakar The Leela, Sahar, Andheri Vs. Bhavan, M. K. East, Mumbai-400 059 Road, Mumbai- 400 020 Pan/Gir No. Aaeck4804H (Applicant) (Respondent) Assessee By Shri Dharan Gandi & Shri Ravi Gupta, Ld. Ars Revenue By Shri Ritesh Misra, Ld. Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 30.01.2026

Section 115JSection 142(1)Section 143(1)Section 143(2)Section 143(3)

Kovalam Leela Raviz Hotel”. The assessee acquired the hotel undertaking of M/s Hotel Leela Venture Ltd. on a going concern basis by way of slump sale under a Scheme of Arrangement sanctioned by the Hon’ble Bombay High Court under sections 391 to 394 of the Companies Act, 1956, vide ... During the course of assessment proceedings, it was noticed that the assessee had acquired Hotel Leela, Kovalam as a going concern under slump sale from M/s Hotel Leela Ventures Ltd. The assessee claimed depreciation aggregating to Rs. 25,86,15,073/- on the assets so acquired. The Assessing Officer then

KOVALAM RESORT PRIVATE LIMITED ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX 2(1)(1), MUMBAI

ITA 6578/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jan 2026AY 2013-14
Section 115JSection 142(1)Section 143(1)Section 143(2)Section 143(3)

Kovalam Leela Raviz Hotel”. The\nassessee acquired the hotel undertaking of M/s Hotel Leela\nVenture Ltd. on a going concern basis by way of slump sale under\na Scheme of Arrangement sanctioned by the Hon'ble Bombay\nHigh Court under sections 391 to 394 of the Companies Act,\n1956, vide ... During the course of assessment proceedings, it was noticed\nthat the assessee had acquired Hotel Leela, Kovalam as a going\nconcern under slump sale from M/s Hotel Leela Ventures Ltd.\nThe assessee claimed depreciation aggregating to Rs.\n25,86,15,073/- on the assets so acquired. The Assessing Officer\nthen

INCOMETAX OFFICER, CHENNAI vs. DOOSAN BOBCAT PRIVATE LIMITED, CHENNAI

In the result, the appeal of the Revenue is dismissed and the CO of assessee is dismissed as not-pressed

ITA 2288/CHNY/2025[2013]Status: DisposedITAT Chennai23 Jan 2026

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2288/Chny/2025 & C.O No.76/Chny/2025 (Arising In Ita No.2288/Chny/2025) िनधा%रण वष% /Assessment Year: 2013-14 The Income Tax Officer, Doosan Bobcat Pvt. Ltd., Htc Towers, 6Th Floor, Corporate Ward-2(1), Vs. Chennai. No.41, Gst Road, Guindy Industrial Estate S.O., Guindy, Chennai – 600 032. Pan: Aaccd 6529L

For Respondent: Mr. Praveen.S, JCIT
Section 250Section 32Section 32(1)(ii)

account of the assessee-company at book value. Doosan International had certain intangible assets in the books of account acquired as part of a slump sale and has been claiming depreciation on the same. In the books of the assessee-company, the intangible assets are recorded post merger ... merger is amortized in the books as per the requirement of the prescribed accounting standards. The goodwill which arose pursuant to the slump sale of IGIL to Doosan International represents a payment made by Doosan International in anticipation of future economic benefits. These benefits are not immediate but generally accrues

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