PRINCIPAL COMMISSIONER OF INCOME TAX -3, KOLKATA vs. M/S. ITC LIMITED

Appeal is allowed to the extent indicated

Bench: HON'BLE JUSTICE SURYA PRAKASH KESARWANI,HON'BLE JUSTICE RAJARSHI BHARADWAJ

55 of 77 section 45, the amount chargeable to income-tax as income of such specified entity under that sub-section which is attributable to the capital asset being transferred by the specified entity, calculated in the prescribed manner:] Provided ………: Provided ……… Provided ………. Provided ………. Provided ………. Provided ………. Provided ………. [Explanation. - For the purposes of this section,- (i)"foreign currency……….; (ii)the conversion

PRINCIPAL COMMISSIONER OF INCOME TAX 1 KOLKATA vs. M/S ITC LTD

Bench: The Learned Tribunal – One By The Assessee & The Other By The Revenue Which Have Been Disposed Of By A Common Order, Impugned In This Appeal. 2. The Revenue Has Raised The Following Substantial Questions Of Law For Consideration :