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“business transfer agreement”

Capital GainsSection 50BSection 50B154 judgments

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)

Supreme Court in the case of Smifs Securities Ltd.(supra).\n9. The CIT(A) recorded that the assessee had entered into a business transfer agreement with THPL, whereby the 'value fashion' business was transferred as a going concern by way of slump sale for a consideration of Rs. 87.82 crores ... concern and not for individual assets or liabilities. He noted that no individual values were assigned to specific assets or liabilities in the business transfer agreement, except for valuations done for regulatory purposes such as stamp duty.\n12. The CIT(A) further observed that the so-called goodwill claimed

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

n3.4 is pertaining to depreciation on intangible assets.\n20. The relevant facts are that the assessee company entered 2\ndifferent business transferred agreement (BTA) with its holding company\nInfosys Ltd. The first BTA was entered as on 1st July 2014 i.e. during the\nF.Y. 2014-15 for transfer of Edge ... during the\nrelevant assessment year, the Finacle and Edgeservices businesses were\ntransferred by Infosys Limited to the appellant pursuant to a duly\nexecuted Business Transfer Agreement. The transfer was carried out on\na going concern basis for a lump-sum consideration, and the appellant\nacquired all assets, liabilities, rights

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

pertaining to depreciation on intangible assets. 20. The relevant facts are that the assessee company entered 2 different business transferred agreement (BTA) with its holding company Infosys Ltd. The first BTA was entered as on 1st July 2014 i.e. during the F.Y. 2014-15 for transfer of Edge suit ... during the relevant assessment year, the Finacle and Edgeservices businesses were transferred by Infosys Limited to the appellant pursuant to a duly executed Business Transfer Agreement. The transfer was carried out on a going concern basis for a lump-sum consideration, and the appellant acquired all assets, liabilities, rights

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

pertaining to depreciation on intangible assets. 20. The relevant facts are that the assessee company entered 2 different business transferred agreement (BTA) with its holding company Infosys Ltd. The first BTA was entered as on 1st July 2014 i.e. during the F.Y. 2014-15 for transfer of Edge suit ... during the relevant assessment year, the Finacle and Edgeservices businesses were transferred by Infosys Limited to the appellant pursuant to a duly executed Business Transfer Agreement. The transfer was carried out on a going concern basis for a lump-sum consideration, and the appellant acquired all assets, liabilities, rights

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

n3.4 is pertaining to depreciation on intangible assets.\n20.\nThe relevant facts are that the assessee company entered 2\ndifferent business transferred agreement (BTA) with its holding company\nInfosys Ltd. The first BTA was entered as on 1st July 2014 i.e. during the\nF.Y. 2014-15 for transfer of Edge ... during the\nrelevant assessment year, the Finacle and Edgeservices businesses were\ntransferred by Infosys Limited to the appellant pursuant to a duly\nexecuted Business Transfer Agreement. The transfer was carried out on\na going concern basis for a lump-sum consideration, and the appellant\nacquired all assets, liabilities, rights

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

pertaining to depreciation on intangible assets. 20. The relevant facts are that the assessee company entered 2 different business transferred agreement (BTA) with its holding company Infosys Ltd. The first BTA was entered as on 1st July 2014 i.e. during the F.Y. 2014-15 for transfer of Edge suit ... during the relevant assessment year, the Finacle and Edgeservices businesses were transferred by Infosys Limited to the appellant pursuant to a duly executed Business Transfer Agreement. The transfer was carried out on a going concern basis for a lump-sum consideration, and the appellant acquired all assets, liabilities, rights

RAVI BANSILAL DARIRA,MUMBAI vs. CIRCLE 15(3)(1), MUMBAI, MUMBAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 5900/MUM/2025[2023-24]Status: DisposedITAT Mumbai28 Jan 2026AY 2023-24

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2023-24 Ravi Bansilal Darira, Deputy Commissioner Of 10Th Floor, Income Tax, Supreme Serenity, Vs. Circle-15(3)(1), 16Th Road, Aayakar Bhavan, Khar Delivery S.O. Mumbai-400020. Mumbai-400052. Pan : Aahpd2499M (Appellant) (Respondent) For Assessee : Shri Vijay Jadhav For Revenue : Shri Annavaran Kosuri Date Of Hearing : 22-01-2026 Date Of Pronouncement : 28-01-2026 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Shri Vijay JadhavFor Respondent: Shri Annavaran Kosuri
Section 143(3)

entire business was transferred to a newly incorporated company, namely, Raviraj Process Controls Private Limited under a duly executed business transfer agreement and all assets, liabilities, contracts, customers and operations stood vested in the company. It was further submitted that the said company has filed its return of income

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)

employee base in pages 10 & 11 of the impugned order. To verify the genuineness of the issue, the Id. CIT(A) examined the business transfer agreement and found satisfied the comprehensive schedules regarding distributors/dealers contract, share distributor/dealer contract, list of intellectual properties, etc. According

ANSHUL SPECIALTY MOLECULES PVT LTD,MUMBAI vs. DCIT, CIRCLE 1(1)(1), MUMBAI

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

ITA 7503/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Jan 2026AY 2020-21

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokaranshul Speciality Dcit Circle Molecules Private 1(1)(1), Mumbai Limited Vs. Aayakar Bhawani, Flexcel Park, „C‟ Wing, S.V. Mumbai-400 020 Road, Nr. 24 Karat Multiplex, Jogeshwari (W), Mumbai- 400102 Pan/Gir No. Aabca4003H (Applicant) (Respondent) Assessee By Shri H. N. Motiwala, Revenue By Shri Surendra Mohan, Sr. Dr Date Of Hearing 20.01.2026 Date Of Pronouncement 22.01.2026

Section 142(1)Section 143(1)Section 143(3)Section 144BSection 250Section 270ASection 32(1)Section 32(1)(ii)

Anmol Antioxidants Pvt. Ltd., Vadodara, by way of slump sale, for an aggregate consideration of Rs. 21,00,00,000/-, pursuant to a Business Transfer Agreement dated 10.02.2020, with effect from 01.03.2020.As per the assessee, the consideration of Rs. 21 crores included Goodwill amounting ... After considering the replies filed by the assessee, the Assessing Officer held that the goodwill was created as a consequence of the Business Transfer Agreement and did not pre- exist in the books of either the transferor or the assessee. The Business Transfer Agreement did not specify any separate consideration

MAERSK TANKERS INDIA PRIVATE LIMITED,MUMBAI vs. THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, MUMBAI

ITA 8376/MUM/2025[2022-2023]Status: DisposedITAT Mumbai20 Jan 2026AY 2022-2023
Section 143(3)Section 144C(1)Section 144C(5)Section 270ASection 92BSection 92B(2)Section 92C

parent company, initiated a global divestment of its Technical\nManagement business to a third party, namely Synergy Marine\nPte. Ltd. Consequent thereto, a Business Transfer Agreement\ndated 28.10.2021 was executed between the assessee and its\ndomestic associated enterprise, Lionheart Shipping Private\nLimited, for divestment of the function providing support services ... valuation\nassumptions, Rule 11UAE, etc., would arise for consideration.\n7. The undisputed factual position relevant to section 92B is such\nthat\ni.\nThe Business Transfer Agreement dated 28.10.2021 is\nbetween the assessee (Maersk Tankers India Private\nLimited) and Lionheart Shipping Private Limited, both\nincorporated and resident in India. This

THERMO FISHER SCIENTIFIC INDIA P. LTD,MUMBAI vs. DCIT 15(3)(1), MUMBAI

ITA 7294/MUM/2018[2014-15]Status: DisposedITAT Mumbai02 Jan 2026AY 2014-15
For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

according the Assessing officer the acquisitions are in the nature\nof amalgamation. Before us, the learned counsel has referred to various\nclauses of business transfer agreement (BTA) in respect of units acquired from\nGSK and CTPL respectively. On perusal of relevant clauses referred, we find\nthat transaction in both

THERMO FISHER SCIENTIFIC INDIA P. LTD,MUMBAI vs. DCIT 15(3)(1), MUMBAI

ITA 7393/MUM/2017[2013-14]Status: DisposedITAT Mumbai02 Jan 2026AY 2013-14
For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

according the Assessing officer the acquisitions are in the nature\nof amalgamation. Before us, the learned counsel has referred to various\nclauses of business transfer agreement (BTA) in respect of units acquired from\nGSK and CTPL respectively. On perusal of relevant clauses referred, we find\nthat transaction in both

THERMO FISHER SCIENTIFIC INDIA P. LTD,MUMBAI vs. DCIT 15(3)(1), MUMBAI

ITA 577/MUM/2017[2012-13]Status: DisposedITAT Mumbai02 Jan 2026AY 2012-13
For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

according the Assessing officer the acquisitions are in the nature\nof amalgamation. Before us, the learned counsel has referred to various\nclauses of business transfer agreement (BTA) in respect of units acquired from\nGSK and CTPL respectively. On perusal of relevant clauses referred, we find\nthat transaction in both

THERMO FISHER SCIENFTIFIC INDIA P. LTD,MUMBAI vs. DCIT 15(3)(1), MUMBAI

ITA 1236/MUM/2016[2011-12]Status: DisposedITAT Mumbai02 Jan 2026AY 2011-12
For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

according the Assessing officer the acquisitions are in the nature\nof amalgamation. Before us, the learned counsel has referred to various\nclauses of business transfer agreement (BTA) in respect of units acquired from\nGSK and CTPL respectively. On perusal of relevant clauses referred, we find\nthat transaction in both

AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

ITA 1840/CHNY/2025[2017-18]Status: DisposedITAT Chennai15 Dec 2025AY 2017-18
For Appellant: Shri. R.Venkata Raman, C.AFor Respondent: Shri. Shiva Srinivas, CIT
Section 142(1)Section 143(2)Section 143(3)Section 250Section 47Section 68

assessee's\nbusiness and the valuation of APDPL's equity shares as on the same date,\ncoinciding with the execution of the Business Transfer Agreement, thereby\ncasting further doubt on the bona fides of the transactions. The Ld.CIT(A) also\nrecorded that the gift and settlement deeds were unsupported ... order\nof the Ld.CIT(A). He submitted that the Ld.CIT(A) held that the net consideration\nof Rs.110.03 crores quantified under the Business Transfer Agreement (“BTA”)\nin connection with the succession of the assessee's sole proprietorship by\nM/s.Amar Prakash Developers Pvt. Ltd. inherently encompassed the purchase\nof the 'Royal

SRF LIMITED,DELHI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 10(1), NEW DELHI, DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 5618/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES ‘H’: NEW DELHI. BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI SUDHIR PAREEK

SRF LIMITED ,DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1449/DEL/2022[2018-19]Status: DisposedITAT Delhi12 Dec 2025AY 2018-19
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES ‘H’: NEW DELHI. BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI SUDHIR PAREEK

SRF LIMITED,NEW DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1448/DEL/2022[2017-18]Status: DisposedITAT Delhi12 Dec 2025AY 2017-18
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES ‘H’: NEW DELHI. BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI SUDHIR PAREEK

MARVELL INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BENGALURU

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

ITA 1608/BANG/2024[2020-21]Status: DisposedITAT Bangalore28 Nov 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Rahul Chaudharym/S. Marvell India Private Limited 10Th Floor, Tower D & E Global Technology Park, Marathahalli Outer Ring Road Devarabeesanahalli Village Varthurhobli Bangalore 560 103 ………. Appellant [Pan: Aaecm5559R]

For Appellant: Sri Chavali NarayanFor Respondent: Sri Muthu Shankar
Section 143(3)Section 144C(1)Section 144C(13)Section 200ASection 234ASection 234BSection 234CSection 270ASection 274Section 28

intangible assets. 7.1. On perusal of records, we find that during the relevant previous year, the Assessee had entered into two separate Business Transfer Agreements to acquire business undertaking of Global Foundries Engineering Pvt. Ltd. (GFEPL) and Aquifina Semi-Conductors India Pvt. Ltd. by way of slump sale transactions ... intangible assets along with the BTA entered by the Company: We humbly wish to submit that the company during AY 2020- 21 through Business transfer Agreement (BTA) had acquired business from the entities viz. Global Foundries Engineering Private Limited and Aquantia Semiconductors India Private Limited. Details of the same

VIACOM 18, MEDIA PVT LTD ,MUMBAI vs. PCIT-8, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 2591/MUM/2025[2019-20]Status: DisposedITAT Mumbai27 Nov 2025AY 2019-20
Section 143(3)Section 144BSection 263Section 32

acquired the “Studio 18” division of ‘Network 18 Media &\nInvestments Pvt. Ltd.' on a going concern basis under slump sale.\nAs per the business transfer agreement, the assessee had acquired\nthe net assets at the value of Rs.3,44,00,309/- against the total\nconsideration of Rs.4

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