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ITAT ruled that Section 56(2)(vii)(c)(ii) does not apply to public limited companies, being exclusively applicable to individuals and HUFs. In a scheme of amalgamation involving share allotment, there is no traditional 'transfer' under Section 47(vii). The High Court-approved amalgamation scheme with its share exchange ratio is conclusive, precluding arguments about discounted share pricing. The tribunal affirmed the CIT(A)'s findings, dismissing the revenue's appeal and holding that the new share issuance does not trigger tax implications under the challenged provision.
ITAT ruled that Section 56(2)(vii)(c)(ii) does not apply to public limited companies, being exclusively applicable to individuals and HUFs. In a scheme of amalgamation involving share allotment, there is no traditional 'transfer' under Section 47(vii). The High Court-approved amalgamation scheme with its share exchange ratio is conclusive, precluding arguments about discounted share pricing. The tribunal affirmed the CIT(A)'s findings, dismissing the revenue's appeal and holding that the new share issuance does not trigger tax implications under the challenged provision.
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