January 29, 2010 : In a recent matter of Star Television Entertainment Ltd¹., the Authority for Advance Rulings (“AAR”) has held, that no capital gains tax liability would arise under the Income Tax Act, 1961 (“ITA”) in respect of transfer of shares/ assets forming part of the terms of an amalgamation. The AAR rejected the plea of the income tax department and refused to deny the benefit of capital gain tax exemption on the ground that the amalgamation is without any commercial or business purpose.