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In the result, both the appeals of the assessee are partly allowed for statistical purposes
Bench: Shri Waseem Ahmed & Shri Soundararajan K
depreciation. 32.4 The ld. DR also contended that the Appellant cannot avoid the application of section 170 merely by splitting the transfer into multiple agreements or spreading it over different years. In substance, the Appellant acquired key revenue-generating businesses of the transferor. ITA Nos.290 - 294/Bang/2025 Page 27