Shared received post amalgamation taxable as per substance of transaction to be Valued Entirely on Different Fundamentals

CIT Vs Nalwa Investment Ltd. (Delhi High Court)

The issue under consideration is whether proceeds release from shares exchange with new shares because of amalgamation process will be taxable under income tax?

High Court states that, under the scheme of amalgamation, the amalgamating company is getting extinguished in the sense that the surviving entity now is only the amalgamated company. However, we cannot ignore the fact that the shares that were with the assessees have

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