Hindustan Coca Cola Beverages (P) Ltd. v.AD.CIT (2025) 233 TTJ 777 / 170 taxmann.com 633/ 122 ITR 290 (Delhi)(Trib)

S. 45 : Capital gains-Cost of acquisition-Slump sale-Adjustment of business impairment loss on land purchased as part of slump sale of business-Indexed cost of acquisition has to be calculated from the actual cost of land acquired by the assessee-Fixed assets schedule pprepared for Comoanies Act has no relevance, no depreciation can be allowed on free hold land-In the absence of proper details, the additions made by the AO are sustained. [S. 32, 48, 50B]

Held that   business impairment loss assessee has recorded in the fixed assets schedule prepared for the purpose of Companies Act has no relevance considering the fact that no depreciation is allowed for the freehold land; assessee having not submitted the cost allocation of the freehold land acquired by way of slump sale along with buildings, the business loss impairment adjustment made by the assessee qua value of freehold land cannot be reduced upon the sale of land. Indexed cost of acquisition has to be calculated from the actual cost of land acquired by the assessee. (AY. 2014-15 to 2016-17)

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