ATLAS COPCO (INDIA) LTD.,PUNE vs. DCIT,CIR-8,, PUNE

In the result, appeal of the Revenue in ITA No

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपीऱ सं. / Ita No.1302/Pun/2010 नििाारण वषा / Assessment Year : 2004-05 The Deputy Commissioner Of Income Tax, Circle-8, Pune. .......अऩीऱाथी / Appellant बिाम / V/S. M/S. Atlas Copco (India) Ltd. Sveanagar, Mumbai-Pune Road, Dapodi, Pune-411 012. Pan: Aaaca4074D ……प्रत्यथी / Respondent

section 35D(2)(c)(iii) of the Act. There is substantial difference between registration of a company and action taken for increase in authorized share capital. In the case of the assessee because of amalgamation proceedings, there was need to increase in authorized share capital and therefore, such expenses cannot be segregated from the main amalgamation proceedings and therefore, these