https://www.taxtmi.com/caselaws?id=410477 For amalgamation-based tax relief under sections 2(1B) and 72A of the Income-tax Act, 1961, the statutory conditions must be tested on the appointed date fixed by the sanctioned scheme. Where the shareholders of the transferor company holding not less than three-fourths in value do not become shareholders of the amalgamated company on that date, the amalgamation does not satisfy the statutory definition for loss carry forward purposes. In that event, the transferee company cannot carry forward or set off the accumulated losses of the amalgamating company, and the loss claim fails for non-compliance with the prescribed prerequisites. en-us Mon, 21 Jun 2021 00:00:00 +0530 Tue, 03 Aug 2021 09:14:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=410477 For amalgamation-based tax relief under sections 2(1B) and 72A of the Income-tax Act, 1961, the statutory conditions must be tested on the appointed date fixed by the sanctioned scheme. Where the shareholders of the transferor company holding not less than three-fourths in value do not become shareholders of the amalgamated company on that date, the amalgamation does not satisfy the statutory definition for loss carry forward purposes. In that event, the transferee company cannot carry forward or set off the accumulated losses of the amalgamating company, and the loss claim fails for non-compliance with the prescribed prerequisites. Case-Laws Income Tax Mon, 21 Jun 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=410477