Under the Income-tax Act, 2025, on the amalgamation of a company with an Indian company:

Section 70(1)(e) of the Income-tax Act, 2025 provides that section 67 does not apply to a transfer, in a scheme of amalgamation, of a capital asset by the amalgamating company to the amalgamated company if the amalgamated company is an Indian company. Hence "The transfer of capital assets by the amalgamating company to the amalgamated Indian company in the scheme of amalgamation is not regarded as a transfer, so no capital gain arises." Section 70(1)(f) similarly protects shareholders who receive shares in the amalgamated Indian company in exchange for their shares. This corresponds to section 47 of the repealed Income-tax Act, 1961.