“business transfer agreement”

Capital GainsSection 50BSection 50B154 judgments

The decision most relied on for business transfer agreement is Champion Engineering Works Ltd. v. CIT (1971) 81 ITR 273 (Bom), CIT v. Bowrisankara Stemp Ferry Co. (165 ITR 63), cited in 66 judgments on BharatTax.

Leading authorities on business transfer agreement

Champion Engineering Works Ltd. v. CIT (1971) 81 ITR 273 (Bom), CIT v. Bowrisankara Stemp Ferry Co.

165 ITR 63 · 1987 · High Court

citing judgments

The case is cited for the principle that when a payment is made for a non-compete agreement which is part of a larger business transfer, the characterisation of the payment depends on whether it is for the enduring benefit of the business or for the loss of potential profits.

Pentasoft Technologies Ltd. v. DCIT

41 Taxmann.com 120 · 2014 · High Court

citing judgments

A non-compete fee paid as part of a business acquisition or transaction constitutes an intangible asset, eligible for depreciation under Section 32(1)(ii) of the Income-tax Act.

Ors. (1987) 165 ITR 63 (Mad), DCIT v. McDowell & Co. Ltd. 291 ITR 107 (Kar.), CIT v. Excel Industries Limited

122 ITR 977 · 1980 · High Court

citing judgments

Expenditure incurred to eliminate competition can be capital in nature, even if it is not simultaneous with the acquisition of a business. The enhancement of lease rent attributable to the elimination of competition is considered capital expenditure.

Triune Energy Services (P.) Ltd. v. DCIT

65 Taxmann.com 288 · 2016 · High Court

citing judgments

When a business is purchased as a going concern, the consideration paid in excess of the value of its tangible assets is classified as goodwill, which is an intangible asset eligible for depreciation without needing a separate valuation.

CIT v. Rai Bahadur Jairam Valji

35 ITR 148 · 1959 · Supreme Court

citing judgments

Compensation received for the cancellation of an agency agreement is a capital receipt if it impairs the assessee's trading structure or results in the loss of a source of income. However, if the contract is terminated in the ordinary course of business, the compensation may be considered a revenue receipt, with classification depending on the specific facts of each case.

Council), V.Damodaran v. CIT Kerala 64 ITR 26(Ker.), Champion Engineering Works Ltd. v. CIT

87 ITR 650 · 1973 · High Court

citing judgments

A payment made to eliminate competition is a capital expenditure, not a deductible business expense, as it secures an enduring benefit.

M/s Tecumesh India Private Limited v. Additional CIT

132 TTJ 129 · ITAT

citing judgments

Payments made to ward off competition, even to a rival dealer, are considered capital expenditure. It is not necessary for such fees to create a monopoly to be classified as capital in nature.

91 ITR 107 (Kar.), CIT v. Excel Industries Limited 122 ITR 995 (Bom.), Hindustan Times Ltd. v. CIT

127 ITR 74 · High Court

citing judgments

Expenditure incurred to eliminate competition is considered capital expenditure. This is particularly true when the expenditure creates an enduring benefit for the assessee.

Judgments citing business transfer agreement

M/S Mhm Holdings Pvt Ltd, Bangalore vs. The Additional Commissioner of Income Tax Range-12, Bangalore

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

ITA 372/BANG/2018[2010-11]Status: DisposedITAT Bangalore25 Nov 2022AY 2010-11

Bench: Smt. Beena Pillai & Ms. Padmavathy S.M/S. Mhm Holding Pvt. Ltd. Vs Acit, Range - 12 Bengaluru No. 52, Bassappa Road Shantinagar Bengaluru 560027 Pan – Aabcm6614L (Appellant) (Respondent) Assessee By: Shri Parthasarathi, Adv. Revenue By: Shri K.R. Narayana, Addl Cit-Dr Date Of Hearing: 23/11/2022 Date Of Pronouncement: 25/11/2022 O R D E R Per: Padmavathy, A.M.

For Appellant: Shri Parthasarathi, AdvFor Respondent: Shri K.R. Narayana, Addl CIT-DR

Section 143(2)Section 14ASection 40Section 50B

provisions of the Act, in so far as it relates to charge and computation of capital gain on slump sale. Perusal of the business transfer agreement dated 01.03.2013 would clearly show that the fulfilment 6 M/s. MHM Holding Pvt. Ltd. of the condition laid down in clause

Deputy Commissioner of Income Tax, Circle- 4(1)(1), Bangalore vs. M/S. Lifestyle International Private Limited, Bangalore

In the result, the assessee’s appeal stands allowed and revenue’s appeal stands dismissed

ITA 93/BANG/2020[2013-14]Status: DisposedITAT Bangalore18 Nov 2022AY 2013-14

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2013-14 M/S. Lifestyle International Pvt. Ltd., 77, Town Centre, The Deputy Building No. 3, Commissioner Of West Wing, Income Tax, Off Hal Airport Road, Circle – 4(1)(1), Yamlur, Vs. Bengaluru. Bengaluru – 560 037. Pan: Aaacl2937J Appellant Respondent & Assessment Year : 2013-14 (By Revenue)

Section 2Section 37Section 43(6)(c)Section 50B

only "Splash" brand as alleged by the learned AO. 1.7. The learned CIT(A) has failed to appreciate that as per Business Transfer Agreement the Appellant has agreed to sell all the assets for a lump sum consideration without any values being assigned to individual assets and it was intended ... slump sale as business income, instead of long term capital gains. 4.1 The learned AR submitted that, the assessee entered into a business transfer agreement with Splash Fashions India Pvt. Ltd. on 29.12.2012 with effect from 01.10.2012 for sale of its "Splash" division, on a going concern and slump sale

Atos It Services Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-1(1)(1), Bangalore

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

ITA 226/BANG/2021[2016-17]Status: DisposedITAT Bangalore25 Aug 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri Dhanesh Bafna, CAFor Respondent: Shri Bijoy Kumar Panda, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 92B(2)Section 92C

claimed depreciation on goodwill of Rs.23,37,85,398. The assessee submitted before the AO that goodwill has arisen out of the business transfer agreement between the assessee and Xerox Business Services India Private Limited (`XBSIPL'). The AO did not allow the depreciation claim on the said goodwill

The Assistant Commissioner of Income Tax, Circle- 1(1), Mysuru vs. M/S. Bhoruka Aluminium Limited, Mysuru

In the result, appeal of the Revenue is allowed

ITA 2551/BANG/2019[2014-15]Status: DisposedITAT Bangalore16 Aug 2022AY 2014-15

Bench: Shri N. V. Vasudevan & Shri Laxmi Prasad Sahuassessment Year : 2014-15 Acit, Vs. M/S. Bhoruka Aluminium Ltd., No.427E, 2Nd Floor, Hebbal Industrial Circle – 1(1), Mysuru. Area, Metagalli, Mysuru – 570 016. Pan : Aaacb 8073 D Appellant Respondent Assessee By : Shri. S. Ramasubramanian, Ca Revenue By : Dr. Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 08.08.2022 Date Of Pronouncement : 16.08.2022 O R D E R Per N. V. Vasudevan:

For Appellant: Shri. S. Ramasubramanian, CAFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 2Section 288Section 35ASection 43Section 43(6)(c)Section 48Section 49Section 50B

Income Tax Act, 1961 (hereinafter called ‘the Act’) on slump sale of one it’s undertaking by the assessee under business transfer agreement dated 01.03.2013, in AY 2014-15. As per section 2(42C) of the Act, ‘slump sale’ means the transfer Page 2 of 18 of one or more ... coating. During the previous year, the assessee effected a slump sale of its aluminum extrusion business to M/s. Bhoruka Extrusions Pvt. Ltd., under business transfer agreement (BTA) dated 01.03.2013. The AO noticed that as per the business transfer agreement clause 3.1.1, the total consideration agreed upon between the parties

Abbott Healthcare P. Ltd, Mumbai vs. ACIT 2(1)(1), Mumbai

ITA 570/MUM/2018[2011-12]Status: DisposedITAT Mumbai02 Aug 2022AY 2011-12

Bench: Shri Vikas Awasthy & Shri Amarjit Singh आअसं.570/मुं/2018 ("न.व. 2011-12) Abbott Healthcare Private Limited., 4, Corporate Park, Sion -Trombay Road, Chembur, Mumbai 400 071. Pan: Aaack-3935-D ..... अपीलाथ" /Appellant बनाम Vs. Asstt. Commissioner Of Income Tax, Circle 2(1)(1), Room No.561, 5Th Floor, Aaykar Bhavan, M.K.Road, Mumbai 400 020 ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : S/Shri Raghavendra Singh/ Lokesh Shah/Kiran Belkar ""तवाद" "वारा/Respondent By : Smt. Monica Khare सुनवाई क" "त"थ/ Date Of Hearing : 04/05/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 02/08/2022 आदेश/ Order Per Vikas Awasthy, Jm:

For Appellant: S/Shri Raghavendra Singh/For Respondent: Smt. Monica Khare

Section 254(2)Section 32Section 32(1)

application is reproduced herein below:- “ 3. During the previous year relevant to Assessment Year 2011-12, the Assessee had entered into a Business Transfer Agreement dated May 21, 2010 with Piramal Healthcare Limited ("Piramal"), in order to acquire Piramal's Base Domestic Formulations business on a slump sale basis ... assessee submitted that assessee company is engaged in the business of manufacturing and trading of pharmaceutical, nutritional , diagnostic and vascular products. A business transfer agreement dated 21/05/2010 was entered into by the assessee with M/s. Piramal Healthcare Ltd. Pursuant to the said agreement the assessee acquired Base Domestic Formulations business

M/S Te Connectivity India Pvt Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Ltu, Circle-1, Bengaluru

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

ITA 2680/BANG/2017[2013-14]Status: DisposedITAT Bangalore18 Jul 2022AY 2013-14

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Sumeet Khurana, CAFor Respondent: Shri V.S. Chakrapani, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 40Section 92

slump sale has been computed correctly in accordance with the provisions of section 50B of the Act.” 65. The assessee has entered into business transfer agreement for sale of tooling parts business as a going concern for a consideration of Rs.10,64,80,000 and claimed capital loss of Rs.1

Loreal India Pvt. Ltd, Mumbai vs. Addl/Jt/Dy/ACIT/ITO/NFAC, Delhi

In the result, the appeal filed by the assessee for AY 2016-17 is treated as partly allowed

ITA 802/MUM/2022[2017-18]Status: DisposedITAT Mumbai29 Jun 2022AY 2017-18

Section 143(3)Section 144CSection 92C

voluminous paper book furnished by the assessee. During the relevant financial year involved in this case, the assessee entered into a business transfer agreement with Rahul Healthcare for purchase of Soap manufacturing unit of Rahul Healthcare as a going concern on the lump-sum basis. The business transfer agreement

L' Oreal India P. Ltd., Mumbai vs. National E-Assessment Centre/ Dy CIT-Circle-7(1)(1), Mumbai

In the result, the appeal filed by the assessee for AY 2016-17 is treated as partly allowed

ITA 1198/MUM/2021[2016-17]Status: DisposedITAT Mumbai29 Jun 2022AY 2016-17

Section 143(3)Section 144CSection 92C

Dy CIT Circle- 12(1)(1), Mumbai vs. M/S Archroma India Pvt Ltd., Thane

In the result, appeal filed by the revenue is dismissed

ITA 590/MUM/2020[2016-17]Status: DisposedITAT Mumbai29 Jun 2022AY 2016-17

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Bledcit – Circle – 12(1)(1) V. M/S. Archroma India Pvt. Ltd., Room No. 128C, 1St Floor 9Th Floor, D Building Aayakar Bhavan, M.K. Road Mbc Park, Ghodbunder Road Mumbai - 400020 Kasawadavali, Thane Mumbai - 400615 Pan: Aaaca8270F (Appellant) (Respondent) Assessee By : Shri Madhur Agrawal Department By : Ms. Shailaja Rai

For Appellant: Shri Madhur AgrawalFor Respondent: Ms. Shailaja Rai

Section 170Section 2(42)Section 2(42)(C)Section 32Section 32(1)(ii)Section 50BSection 5O

otherwise than death. 20. In the present case we find that assessee had acquired the said assets under slump sale. There is a business transfer agreement and by way of this agreement the assessee has purchased an undertaking under slump sale. In our considered opinion the facts in the present ... case clearly show that the assessee company has acquired the assets under a business transfer agreement. Hence it has succeeded the transferee company. The provisions of section 170 are clearly applicable on the facts of the present case. 21. The submission of the learned counsel of the assessee that there

M/S I & B Seeds Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore

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

ITA 3415/BANG/2018[2015-16]Status: DisposedITAT Bangalore15 Jun 2022AY 2015-16

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2015-16

For Appellant: Shri Nitish Ranjan, A.RFor Respondent: Shri Sankar Ganesh K, D.R

Section 43(1)

goodwill paid was not only towards the value of assets and liabilities taken over but was also towards various clauses in the Business Transfer Agreements (BTA) such as non-compete and non solicitation, transfer of distribution network, customer database, material contracts, value of ongoing Research & Development along with ... concern was taken over by the assessee company. 3. During appellate proceedings the assessee has made detailed submissions. The assessee referred to the business transfer agreements (BTAs) with the two concerns purchased by it in slump sale. The BTAs define the words 'Intellectual Property Rights' and 'know-how'. The assessee

M/S. Te Connectivity India Private Limited (Successor in Interest to Tyco Electronics Systems India Private Limited), Bangalore vs. Commissioner of Income Tax, Appeals -14, Ltu, Bangalore

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

ITA 720/BANG/2021[2013-14]Status: DisposedITAT Bangalore01 Jun 2022AY 2013-14

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Sumeet Khurana, A.RFor Respondent: Shri Sankar Ganesh K., D.R

Section 234Section 234B

that the Company did not have any business income during the year due to transfer of its Energy Trade and Export business vide business transfer agreement dated September 23. 2010 with Raychem RPG Private Limited (`RRI.; or 'the purchaser') on a going concern basis and the sale was with effect ... fact the Company had agreed to provide transitional services for and on behalf of RRL during the transition period as per the Business Transfer Agreement and the revenue (if any) pertains to RRL and might have erroneously been reflected in Form 26AS of the Company 5. The Learned

M/S. Te Connectivity Services India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

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

ITA 300/BANG/2021[2016-17]Status: DisposedITAT Bangalore26 May 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.300/Bang/2021 Assessment Year : 2016-17

For Appellant: Shri Sriram Sheshadri & Ms. Amulya K., CAsFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(3)

ordinary in nature. It is the case of the assessee that goodwill is on account of acquisition of units through slump sale under Business Transfer Agreement and in these circumstances, amortization of goodwill is an extra ordinary item and is not pertaining to the regular operation of the taxpayer, hence

M/S. Sogefi Mnr Filtration India Pvt Lld, Bangaluru vs. Deputy Commissioner of Income Tax, Circle-12(2), Bangaluru

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

ITA 2076/BANG/2018[2011-12]Status: DisposedITAT Bangalore19 Apr 2022AY 2011-12

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

For Appellant: NoneFor Respondent: Shri. Priyadarshi Mishra, Addl. CIT(DR)(ITAT), Bengaluru

Section 143(3)

books of the company. The total un-secured loans of partners stood at Rs.13,13,13,508/-. 5. The Assessee entered into a business transfer agreement with one M/s.Filtrauto, SA, France wherein the later had agreed to acquire 60% of the equity shares of the Assessee subject to due — diligence

M/S. Sogefi Mnr Filtration India Pvt Ltd, Bangaluru vs. Deputy Commissioner of Income Tax, Circle-12(2), Bengaluru

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

ITA 2075/BANG/2018[2010-11]Status: DisposedITAT Bangalore19 Apr 2022AY 2010-11

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

For Appellant: NoneFor Respondent: Shri. Priyadarshi Mishra, Addl. CIT(DR)(ITAT), Bengaluru

Section 143(3)

M/S. Sogefi Mnr Filtration India Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax, Circle-12(2), Bengaluru

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

ITA 2074/BANG/2018[2009-10]Status: DisposedITAT Bangalore19 Apr 2022AY 2009-10

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

For Appellant: NoneFor Respondent: Shri. Priyadarshi Mishra, Addl. CIT(DR)(ITAT), Bengaluru

Section 143(3)

M/S Te Connectivity India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-2 Ltpu, Bangalore

In the result, the appeal by the assessee is treated as partly allowed for 37

ITA 3373/BANG/2018[2014-15]Status: DisposedITAT Bangalore25 Feb 2022AY 2014-15

Bench: Shri N. V. Vasudevan & Shri B. R. Baskaranit(Tp)A No.3373/Bang/2018 Assessment Year : 2014-15 M/S. Te Connectivity India Private Limited, Vs. Acit, Te Park, 22B, Doddenakundi Corporation, 2Nd Circle - 2, Large Taxpayer Unit, Phase, Industrial Area, Whitefield Road, Bengaluru. Bengaluru – 560 048. Pan : Aabct 7374 C Assessee Respondent Assessee By : Shri. Sriram Seshadri, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 22.02.2022 Date Of Pronouncement : 25.02.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. Sriram Seshadri, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C

Raychem RPG Private Limited ("RRPGL"), a JV between TE Connectivity Group and the RPG Group, on a slump purchase basis under a Business Transfer Agreement ("BTA"). [BTA in Pg. 236 of Paperbook - Part A; Affirmative vote agreement in Pg. 314 of Paperbook - Part A; Note on accounting the acquisition

ACIT Cir- 2(1) (1), Mumbai vs. Infrasoft Technologies Ltd, Mumbai

In the result, the appeal filed by the revenue is hereby dismissed

ITA 261/MUM/2021[2016-17]Status: DisposedITAT Mumbai31 Jan 2022AY 2016-17

For Appellant: Shri Anuj KishnadwalaFor Respondent: Shri Mehul Jain (Sr. AR)

Section 143(2)Section 32(1)

intangible assets i.e. goodwill and customer contracts: 3 A.Y.2016-17 61.1 Brief facts of the case are that the appellant company had entered into > business transfer agreement with KPIT Cummins infosystems Ltd. in FY 2011-12 i for acquiring software business of the said company, which comprised of following intangible assets ... business contracts - Rs.10,89,00,000/- b) Goodwill - Rs.8,04,00,000/ (part of which was capitalized in FY 2011-12 as per Business Transfer Agreement) 6.1.2 The appellant has been claiming depreciation on such intangible assets from assessment year 2012-18 onwards which are being disallowed

Gbt India Private Limited, Delhi vs. National E-Assesment Centre, New Delhi

In the result, the appeal of the assessee is allowed and Stay application is accordingly held to be infructuous

ITA 462/DEL/2021[2016-17]Status: DisposedITAT Delhi06 Jan 2022AY 2016-17

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing)

For Appellant: Shri Himanshu Sinha, Adv. &For Respondent: Shri Surendra Pal

Section 143(3)Section 144C(13)

corporate travel business segment and transferred GBT assets, operations, employees and shares of certain Amex affiliates to GBT III BV. A local business transfer agreement was entered between American Express India Pvt. Ltd. (AEIPL) and the assessee on 1 June, 2014 under which the corporate travel business division in India ... acquiring of Corporate Travel (‘CT’) division of American Express India Pvt. Ltd. (‘AEIPL’) on 'slump sale' as a going concern basis vide Local Business Transfer Agreement ('LTBA') dated June 1, 2014. 3.2.1 According to the Assessing Officer, depreciation claimed by the assessee on goodwill was not an allowable deduction since

DCIT, New Delhi vs. M/S Glf Lifestyle Pvt. Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 4556/DEL/2016[2012-13]Status: DisposedITAT Delhi09 Dec 2021AY 2012-13

Bench: Shri G.S.Pannu & Shri Kul Bharat[Assessment Year : 2012-13] Dcit, Vs Glf Lifestyle Pvt.Ltd., Circle-10(1), Flat No.3A/1, Taj Apartment, C.R.Building, Rao Tula Ram Marg, New Delhi-110002. New Delhi-110002. Pan-Aaecg3087E Appellant Respondent Appellant By Shri Ved Jain, Adv. Respondent By Shri Umesh Takyar, Sr.Dr Date Of Hearing 03.11.2021 Date Of Pronouncement 09.12.2021

Section 143(3)Section 32(1)Section 32(1)(ii)

business and commercial rights which include purchase of 'Samsaara' Brand', employees, intellectual property rights, business records, trademarks as reflecting in clause 2.2 of business transfer agreement (PB Pg.59) (iii) Areva T & D India Ltd. v. DCIT [2012] 345 ITR 421 (Delhi High Court) Ld. AO observed that in the above ... which comprised, inter alia, Samsaara brand, business contracts, employees, intellectual property rights, business records, trademarks, copyrights etc. as reflecting in clause 2.2 of business transfer agreement at page 59 of paper book. The assessee-company while filing its return claimed depreciation under section 32(1)(ii) with respect

DCIT Central Circle-3, New Delhi vs. Modtech Industries, New Delhi

In the result, since the assessment order is set aside on legal issue, therefore, there is no need to decide the additions on merits which are left with academic discussion only

ITA 8783/DEL/2019[2015-16]Status: DisposedITAT Delhi13 Oct 2021AY 2015-16

Bench: Shri Amit Shukla & Prashant Maharishi

For Appellant: Shri Salil Aggarwal, Sr. AdvFor Respondent: Shri J.K. Mishra, CIT-DR

Section 132(1)Section 143(2)Section 153ASection 153CSection 153DSection 50B

Page no 39-51 of Annexure Ad) Page nos. 53 and 54 of Annexure A-2 (-2 (locker at OBC) being copy of Business Transfer Agreement (BTA) dated 01.04.2014 between M/s Modtech Industries and M/s Mars Industries Pvt. Ltd. (kindly see pages 431 to 442 of PB - II). Locker ... page 26 to 27 of this synopsis). e) Page no 51 to 94 of Annexure A-1 (locker at ICICI Bank) Copy of Business Transfer Agreement (BTA) dated 11.06.2014 between M/s Dorset India Pvt. Ltd. and M/s I.T.As. No.8045, 8046, 8783/DEL/2019 10 Dorset Kaba Security Pvt. Ltd (kindly see pages