section 2(47) and observed that the assessee has transferred whole plant and handed over possession alongwith plant Shri Ramesh Chandra Vaish v. ACIT, Central Circle, Allahabad, U.P. ITA Nos.59 & 100 /ALLD/2019 AYs:-2014-15 & 2015-16 and machinery etc. to the buyer and the buyer is also running the plant. As the possession of the said plant was handed