Assessee-company was engaged in bottling and marketing beverages under the Coca-Cola brand-It agreed to transfer its entire bottling and marketing business as a going concern for a total consideration of about Rs. 56.23 crores. Sale encompassed all assets, marketing network and goodwill, and included non-compete obligations. Assessee asserted that no individual values were assigned to specific assets as transfer was on a slump basis Tribunal held that since assessee sold its business as a going concern on a lump-sum basis without any individual values to various assets, the transaction in question fell within the definition of a slump sale as set out in section 2(42C). Tribunal held that since the entire business, together with all assets and liabilities, was sold as a going concern on a lump-sum basis, the provisions of section 50B and section 41(2) would not be applicable. Court held that revenue could not artificially fragment a transaction to tax portions thereof under different heads.  (AY. 1998-99)