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    <title>1987 (12) TMI 89 - ITAT MADRAS-A</title>
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    <description>In capital gains computation on shares received in amalgamation, the Tribunal held that the revenue&#039;s additional ground was admissible because it arose from the same controversy and required no fresh facts. Reading sections 47(vii), 49(2) and 55(2)(i) together, it held that the assessee could substitute the fair market value as on 1-1-1964 for the deemed cost of the amalgamated shares. Separate deduction for bonus shares in the amalgamating companies was disallowed, as that cost was embedded in the overall shareholding. For valuation as on 1-1-1964, the 6% capitalisation rate applied, and averaging the yield and break-up value methods was impermissible.</description>
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    <pubDate>Tue, 22 Dec 1987 00:00:00 +0530</pubDate>
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      <title>1987 (12) TMI 89 - ITAT MADRAS-A</title>
      <link>https://www.taxtmi.com/caselaws?id=69140</link>
      <description>In capital gains computation on shares received in amalgamation, the Tribunal held that the revenue&#039;s additional ground was admissible because it arose from the same controversy and required no fresh facts. Reading sections 47(vii), 49(2) and 55(2)(i) together, it held that the assessee could substitute the fair market value as on 1-1-1964 for the deemed cost of the amalgamated shares. Separate deduction for bonus shares in the amalgamating companies was disallowed, as that cost was embedded in the overall shareholding. For valuation as on 1-1-1964, the 6% capitalisation rate applied, and averaging the yield and break-up value methods was impermissible.</description>
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      <pubDate>Tue, 22 Dec 1987 00:00:00 +0530</pubDate>
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