DCIT - 8(2)(1), MUMBAI vs. SIEMENS TECHNOLOGY AND SERVICES PVT. LTD., MUMBAI
In the result, the appeals of the revenue are dismissed and appeal of the assessee is partly allowed
ITA 3247/MUM/2018[2005-06]Status: DisposedITAT Mumbai12 Oct 2022AY 2005-06
Bench: Shri Kuldip Singh & Shri Amarjit Singh
For Appellant: P.J. Pardiwala &For Respondent: Ashok Kumar Kardam
Section 10ASection 143(2)Section 143(3)
Section 1042) in its correct perspective and thereby has arrived at erroneous conclusion.
5. According to the learned counsel, the provisions of Section 101(2) would apply only if the undertaking is not formed by splitting up or reconstruction of the business already in existence. In the present matter