The Revenue has filed against the order of Tribunal  which has dismissed the appeals of the Revenue. On behalf of Revenue it was contended that though the amalgamation is approved by Gujarat High Court  cash payments and interests were paid till date of Search. According to Revenue there was capital gains which was not offered to tax.  The submission that the amount involved is below monitory limit is also not accepted.      Allowing the appeal of the Revenue the Court held that Assessment has to be made on the basis of records actual instead of on  notional basis. Matter remanded to the Assessing Officer. (BP. 1-4 1998 to 15-12 1998)