Dismissing the appeal of the revenue the Court held that the provisions of section 28(iv) of the Act make it clear that the amount reflected in the balance sheet of the assessee under the head reserves and surplus cannot be treated as a benefit or perquisite arising from business or exercise of profession. The difference in amount post amalgamation was the amalgamation reserve and it cannot be said that it was out of normal transaction of the business being capital in nature, which arose on account of amalgamation of four companies, it cannot be treated as falling under section 28(iv). Followed CIT v. Stads Ltd. (2015) 373 ITR 313 (Mad.)(HC). (AY.2006-07)