as per section 47 if in a scheme of amalgamation any transfer of capital assest is made by amalgamating company to the amalgamated company then it is not treated as transfer.... but what is capital asset for the amalgamating company here???
Capital asset for the amalgamating company is the same before amalgamation. But since transfer of such capital asset is not regarded as transfer, then any gain/loss arising from such transfer shall not be chargeable u/h capital gain.
the fixed assets stood in the name of amalgamating company immediately before the date of amalgamation is the capital asset and transfer of such capital asset to amalgamated company not treated as transfer as per section 47