Bench: HON'BLE MR. JUSTICE R. MAHADEVAN
158 ITR 102 (SC) 10 Commissioner of Income-Tax15 and Commissioner of Income-Tax v. Excel Industries Ltd. and another16. Even if the fair market value of the shares allotted in the amalgamated company on the date of allotment exceeds the book value of the shares in the amalgamating company, such appreciation is purely notional. Real income would arise only