Held that  the Commissioner (Appeals) had minutely examined the business transfer agreement and noted that the unit was not sold as a going concern but the assets were sold as individual assets, the valuation had been done separately, the valuation of the land had been separately mentioned in the valuer’s report and that the assessee had not transferred the undertaking with all the assets and liabilities. The Tribunal re-examined the facts and found that the transferee had not taken over all the loans and liabilities. Section 50B was not applicable. (AY. 2005-06)