https://www.taxtmi.com/caselaws?id=759935 A reserve created on amalgamation as a book-entry balancing adjustment in a sanctioned scheme was treated as part of a capital restructuring exercise, not as a revenue benefit or perquisite arising from business or profession, so section 28(iv) did not apply and the addition was deleted. The amalgamation also satisfied the statutory requirements for exemption under section 47(vi), as the transfer of capital assets in the scheme was not regarded as a transfer; once that exemption applied, section 56(2)(x) was also excluded in respect of property received under the merger. The transaction was therefore tax neutral. en-us Tue, 08 Oct 2024 00:00:00 +0530 Fri, 11 Oct 2024 08:58:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759935 A reserve created on amalgamation as a book-entry balancing adjustment in a sanctioned scheme was treated as part of a capital restructuring exercise, not as a revenue benefit or perquisite arising from business or profession, so section 28(iv) did not apply and the addition was deleted. The amalgamation also satisfied the statutory requirements for exemption under section 47(vi), as the transfer of capital assets in the scheme was not regarded as a transfer; once that exemption applied, section 56(2)(x) was also excluded in respect of property received under the merger. The transaction was therefore tax neutral. Case-Laws Income Tax Tue, 08 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759935