https://www.taxtmi.com/caselaws?id=11739 For surtax computation, a shortfall arising on amalgamation between the book value of net assets acquired and the consideration paid was not treated as a capital reserve includible in capital under rule 1(iii) of the Second Schedule. The analysis turned on Explanation 1 to rule 2, which excludes reserves brought into existence by creating or increasing a book asset through valuation or similar accounting treatment. On the facts, the shortfall resulted from the higher historic book value at which the acquired assets were carried, so it was treated as a reserve created by the assessee's accounting treatment rather than a statutory capital component. en-us Thu, 17 Jul 2003 00:00:00 +0530 Sun, 07 Feb 2010 12:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=11739 For surtax computation, a shortfall arising on amalgamation between the book value of net assets acquired and the consideration paid was not treated as a capital reserve includible in capital under rule 1(iii) of the Second Schedule. The analysis turned on Explanation 1 to rule 2, which excludes reserves brought into existence by creating or increasing a book asset through valuation or similar accounting treatment. On the facts, the shortfall resulted from the higher historic book value at which the acquired assets were carried, so it was treated as a reserve created by the assessee's accounting treatment rather than a statutory capital component. Case-Laws Income Tax Thu, 17 Jul 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=11739