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of Section 47(vii) exemption was held confined to transfers of capital assets on amalgamation and inapplicable where the assessee's shares in the amalgamating company were held as stock-in-trade; in such cases, taxability is governed by Section 28 as business income. For Section 28, mere sanction/appointed date does not trigger charge; the taxable event arises only on actual allotment of new shares, and only if the substituted shares confer a real, presently realisable commercial benefit with ascertainable value. Whether the shares were stock-in-trade or investment, and whether the allotted shares were freely realisable/subject to restrictions, was treated as fact-dependent with burden on Revenue; matter was remitted to the Tribunal, while the legal principle was decided in Revenue's favour and the HC judgment affirmed. - SC
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