Reserve arising out of amalgamation is capital reserve and hence not taxable u/s. 28(iv): ITAT Mumbai

DCIT Vs Samagra Wealthmax private Limited (ITAT Mumbai)

ITAT Mumbai held that reserve arising out of amalgamation is capital in nature and cannot be treated as revenue under the ambit of section 28(iv) of the Income Tax Act.

Facts- Assessee is a Company engaged in the business of Real Estate. The assessee is a Company incorporated under the Companies Act and during the year, with an intent to simplify the group structure, rationalize the administrative overhead and to achieve greater administrative efficiency, M/s Celina Buildcon and Infra Private Ltd. was a

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