Tax On share issue

In order to tax as capital gain,
  > there must be capital assets u/s 2(14)
  > there must be transfer u/s 2(47)

Now question arise - why share/debenture issue by co.is not taxable as capital Gain in hand of Co. although,    > share is the capital assets of the co. u/s 2(14)
                   > It is transfer u/s 2(47)
Here it is noted that above transaction is not cover under u/s 46(1) i.e distribution of capital assets in case of liquidation of the co.is not a transfer in hand of Co.

friends please give your answer with referance to Sec. I am waiting your suggestion.......