https://www.taxtmi.com/caselaws?id=62576 The Tribunal held that the provisions of Section 47(v) of the Income-tax Act were not applicable as the transfer of assets between the subsidiary and holding company was invalidated due to a change in holding company status. The assessee was denied the benefit of Section 47(v). Regarding the computation of capital gains under Section 45, the Tribunal ruled that without determining the market value of all assets exchanged, it was impossible to ascertain any profits or gains. As there was no provision for computing capital gains based on market value in asset exchanges, the assessee was not liable to tax under Section 45. The appeal of the assessee was partly allowed, and the revenue's appeal was dismissed. en-us Mon, 20 Mar 1995 00:00:00 +0530 Thu, 20 Jan 2011 14:33:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=62576 The Tribunal held that the provisions of Section 47(v) of the Income-tax Act were not applicable as the transfer of assets between the subsidiary and holding company was invalidated due to a change in holding company status. The assessee was denied the benefit of Section 47(v). Regarding the computation of capital gains under Section 45, the Tribunal ruled that without determining the market value of all assets exchanged, it was impossible to ascertain any profits or gains. As there was no provision for computing capital gains based on market value in asset exchanges, the assessee was not liable to tax under Section 45. The appeal of the assessee was partly allowed, and the revenue's appeal was dismissed. Case-Laws Income Tax Mon, 20 Mar 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=62576