https://www.taxtmi.com/caselaws?id=467666 Shares issued under a court-approved amalgamation scheme are treated as not constituting a transfer in the shareholder's hands under section 47(vii) of the Income-tax Act. Because there is no transfer, section 45 has no role in computing capital gains. The receipt of shares in such an amalgamation is also not receipt of property for inadequate consideration, so section 56(2)(vii)(c)(ii) does not apply. The later exclusion for transactions not regarded as transfers was treated as clarificatory and consistent with the statutory scheme of uniform tax treatment for genuine amalgamations. en-us Fri, 18 Oct 2024 00:00:00 +0530 Sat, 28 Mar 2026 12:18:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467666 Shares issued under a court-approved amalgamation scheme are treated as not constituting a transfer in the shareholder's hands under section 47(vii) of the Income-tax Act. Because there is no transfer, section 45 has no role in computing capital gains. The receipt of shares in such an amalgamation is also not receipt of property for inadequate consideration, so section 56(2)(vii)(c)(ii) does not apply. The later exclusion for transactions not regarded as transfers was treated as clarificatory and consistent with the statutory scheme of uniform tax treatment for genuine amalgamations. Case-Laws Income Tax Fri, 18 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467666