Supreme Court clarifies when share substitution on amalgamations is taxable under S. 28 Income Tax Act
Business profits must be concrete and commercially realisable, not mere paper adjustments. In amalgamation, substitution of shares that yield realisable assets of definite value constitutes taxable income under Section 28 of Income Tax Act, 1961, guided by the doctrine of real income to tax genuine gains while avoiding illusory ones.
