PRINCIPAL COMMISSIONER OF INCOME TAX -3, KOLKATA vs. M/S. ITC LIMITED
Appeal is allowed to the extent indicated
ITA/125/2018HC Calcutta27 Jun 2024
Bench: HON'BLE JUSTICE SURYA PRAKASH KESARWANI,HON'BLE JUSTICE RAJARSHI BHARADWAJ
d) of
section 269UA.
Explanation 2.—For the removal of doubts, it is hereby clarified that
"transfer" includes and shall be deemed to have always included
disposing of or parting with an asset or any interest therein, or
creating any interest in any asset in any manner whatsoever, directly
or indirectly, absolutely or conditionally, voluntarily or involuntarily