C.I.T., COCHIN vs GRACE COLLIS — C.A. No. 4437 - 4445/1997

Case Summary: C.I.T., Cochin v. Grace Collis (2001) The Supreme Court allowed the Revenue's appeal, holding that shareholders' rights in shares of an amalgamating company were "transferred" (within the meaning of Section 2(47) of the Income Tax Act) when those shares were extinguished upon amalgamation, even absent a direct property transfer. Consequently, Section 49(2) applied, requiring capital gains on the subsequent sale of allotted shares in the amalgamated company to be computed using the original cost of amalgamating company shares as the deemed cost basis. This case analysis is maintained by casestatus.in based on publicly available court records.