The ITAT ruled in favour of the assessee, concluding that, no benefit or perquisite arose from the amalgamation scheme. The assessee neither became richer nor poorer through the process. It merely converted indirect ownership to direct ownership. The capital reserve entry was merely a book entry required for accounting purposes under the double-entry system. The capital reserve was capital in nature and not revenue, making Section 28(iv) inapplicable. It was further confirmed that the amalgamation is covered by the exemption provided under section 47(vi), making section 56(2)(x) inapplicable.(AY. 2008-09)