AMALGAMATION

Section No Section Heading

2 Definitions
10A Special provision in respect of newly established undertakings in free trade zone, etc
10AA Special provisions in respect of newly established Units in Special Economic Zones
10B
Special provisions in respect of newly established hundred per cent export-oriented
undertakings
32 Depreciation
32A Investment allowance
32AC Investment in new plant or machinery
33 Development rebate
33A Development allowance
34 Conditions for depreciation allowance and development rebate
35 Expenditure on scientific research
35A Expenditure on acquisition of patent rights or copyrights
35AB Expenditure on know-how
35ABB Expenditure for obtaining licence to operate telecommunication services
35D Amortisation of certain preliminary expenses
35DD Amortisation of expenditure in case of amalgamation or demerger
35DDA Amortisation of expenditure incurred under voluntary retirement scheme
35E Deduction for expenditure on prospecting, etc., for certain minerals
41 Profits chargeable to tax
42
Special provision for deductions in the case of business for prospecting, etc., for
mineral oil
43
Definitions of certain terms relevant to income from profits and gains of business or
profession
43C Special provision for computation of cost of acquisition of certain assets
44DB
Special provision for computing deductions in the case of business reorganization of co-
operative banks
47 Transactions not regarded as transfer
72A
Provisions relating to carry forward and set off of accumulated loss and unabsorbed
depreciation allowance in amalgamation or demerger, etc
72AA
Provisions relating to carry forward and set-off of accumulated loss and unabsorbed
depreciation allowance in scheme of amalgamation of banking company in certain
cases
72AB
Provisions relating to carry forward and set off of accumulated loss and unabsorbed
depreciation allowance in business reorganisation of co-operative banks
79 Carry forward and set off of losses in the case of certain companies
80-IA
Deductions in respect of profits and gains from industrial undertakings or enterprises
engaged in infrastructure development, etc.
80-IB
Deduction in respect of profits and gains from certain industrial undertakings other
than infrastructure development undertakings
80JJAA Deduction in respect of employment of new workmen.
115VY Amalgamation.
155 Other amendments.
Fourth Schedule

APPENDIX -


Section 2
[1B] Merger of one or more companies with another company or merger of two or more companies
to form one company such that all the assets and liabilities of the amalgamating company become
the assets and liabilities of the amalgamated company and shareholders holing not more than 3/4
th

in value of shares in the amalgamating company(s) become shareholder of the amalgamated
company.
Section 10A
Where any undertaking of an Indian company which is entitled to the deduction under this section
regarding deduction of profits of article or thing or computer software is transferred, before the
expiry of the period specified in this section, to another Indian company in a scheme of
amalgamation, the provisions of this section shall, as far as may be, apply to the amalgamated
company as they would have applied to the amalgamating company if the amalgamation had not
taken place.
Section 10AA
Where any undertaking of an Indian company which is entitled to the deduction under this section
regarding deduction of profits from manufacturing or producing articles or things or providing any
services during the previous year relevant to the assessment year is transferred, before the expiry of
the period specified in this section, to another Indian company in a scheme of amalgamation, the
provisions of this section shall, as far as may be, apply to the amalgamated company as they would
have applied to the amalgamating company if the amalgamation had not taken place.
Section 10B
Where any undertaking of an Indian company which is entitled to the deduction under this section
regarding deduction of profits derived by a hundred per cent export-oriented undertaking from the
export of articles or things or computer software during the previous year relevant to the
assessment year is transferred, before the expiry of the period specified in this section, to another
Indian company in a scheme of amalgamation, the provisions of this section shall, as far as may be,
apply to the amalgamated company as they would have applied to the amalgamating company if the
amalgamation had not taken place.
Section 32
(1) Aggregate deduction in respect of depreciation of tangible and intangible assets allowed to
amalgamating company and the amalgamated company in case of amalgamation shall not exceed
the amount calculated as if the succession has not taken place.
In this section, "sold" includes a transfer by way of exchange or a compulsory acquisition but does
not include a transfer, in a scheme of amalgamation, of any asset by the amalgamating company to
the amalgamated company where the amalgamated company is an Indian company or in the
scheme of amalgamation of a banking company.
Section 32A
(5) Any allowance received under this section shall be deemed to be wrongly made for the purposes
of this Act if (a) the investment in the ship, aircraft, machinery or plant is sold or transferred by the
assessee to any person before the expiry of 8 years; (b) or utilise amount credited as Investment
Allowance Reserve Account for 10 years
Nothing in this clause (a) of this sub section shall apply where the sale or transfer of the ship,
aircraft, machinery or plant is made in connection with the amalgamation or succession.
Section 32AC
Any allowance received under this section regarding deduction of amount on capital asset for
production of article or thing will be reversed if the new asset acquired and installed by the assessee
is sold within a period of five years from the date of installation and is applicable in case of
amalgamation also.
Section 33
Any development rebate in respect of a new ship or new machinery or plant shall continue to the
amalgamated company in the scheme of amalgamation, provided the amalgamated company shall
continue to fulfil the conditions mentioned in section 34(3) in respect of the reserve created by the
amalgamating company and within which such new ship, new machinery or plant shall not be sold
and in case of any default, section 155(5) shall apply.
Section 33A
Any allowance under this section shall be deemed to have been wrongly made for the purposes of
this Act, if any such land is sold or otherwise transferred by the assessee to any person at any time
before the expiry of eight years from the end of the previous year in which the deduction was
allowed.
The above provisions shall not apply where the land is sold to the government or related authorities
or where transfer of land is made in connection with amalgamation or succession.

Any development allowance in respect of such land shall continue to the amalgamated company in
the scheme of amalgamation, provided the amalgamated company shall continue to fulfil the
conditions of sub section 3 in respect of the reserve created by the amalgamating company and
within which such new ship, new machinery or plant shall not be sold and in case of any default,
section 155(5) shall apply. The same goes in case of succession of the firm by a company.
Section 34
This section related to depreciation allowance and development rebate shall not apply where the
sale or transfer of the ship, machinery or plant is made in connection with the amalgamation or
succession, referred to in sub-section (3) or sub-section (4) of section 33.
Section 35
(5) Where, in a scheme of amalgamation, the amalgamating company sells or otherwise transfers to
the amalgamated company (being an Indian company) any asset representing expenditure of a
capital nature on scientific research, the provisions of this section shall, as far as may be, apply to
the amalgamated company as they would have applied to the amalgamating company if the latter
had not so sold or otherwise transferred the asset.
Provided the amalgamating company shall not be allowed the deduction under clause (ii) or clause
(iii) of sub-section (2)
Section 35A
(6) Where, in a scheme of amalgamation, the amalgamating company sells or otherwise transfers
the rights so acquired to the amalgamated company (being an Indian company), the provisions of
this section shall, as far as may be, apply to the amalgamated company as they would have applied
to the amalgamating company if the amalgamation had not taken place.
Section 35AB
(3) Where there is a transfer of an undertaking under a scheme of amalgamation and the
amalgamating company is entitled to a deduction under this section regarding expenditure on know-
how, then, the amalgamated company, as the case may be, shall be entitled to claim deduction
under this section in respect of such undertaking to the same extent and in respect of the residual
period as it would have been allowable to the amalgamating company, as the case may be, had such
amalgamation not taken place.
Section 35ABB
(6) Where, in a scheme of amalgamation, the amalgamating company sells or otherwise transfers
the licence to the amalgamated company (being an Indian company), the provisions of this section
shall, as far as may be, apply to the amalgamated company as they would have applied to the
amalgamating company if the amalgamation had not taken place.
Section 35D
Where the undertaking of an Indian company which is entitled to the deduction under this section
for preliminary expenses is transferred to another Indian company in a scheme of amalgamation, the
provisions of this section shall, as far as may be, apply to the amalgamated company as they would
have applied to the amalgamating company if the amalgamation had not taken place.
Section 35DD
Where an assessee, being an Indian company, incurs any expenditure wholly and exclusively for the
purposes of amalgamation or demerger of an undertaking, the assessee shall be allowed a deduction
of an amount equal to one-fifth of such expenditure for each of the five successive previous years
beginning with the previous year in which the amalgamation or demerger takes place.
Section 35DDA
Where the assessee, being an Indian company, is entitled to the deduction under this section
regarding amortisation of expenditure incurred under VRS and the undertaking of such Indian
company entitled to the deduction under this section is transferred to another Indian company in a
scheme of amalgamation, the provisions of this section shall, as far as may be, apply to the
amalgamated company as they would have applied to the amalgamating company if the
amalgamation had not taken place.
However, no deduction shall be allowed to the amalgamated company for the previous year in
which amalgamation as the case may be, takes place.
Section 35E
Where the undertaking of an Indian company which is entitled to the deduction under this section
regarding deduction for expenditure on prospecting, etc., for certain minerals is transferred to
another Indian company in a scheme of amalgamation, the provisions of this section shall, as far as
may be, apply to the amalgamated company as they would have applied to the amalgamating
company if the amalgamation had not taken place.
Section 41
Succession in the said section includes amalgamation but sold does not include amalgamation.


Section 42
Where in a scheme of amalgamation, the amalgamating company sells or otherwise transfers the
business to the amalgamated company (being an Indian company), the provisions of this section
shall, as far as may be, apply to the amalgamated company as they would have applied to the
amalgamating company if the amalgamation had not taken place.
Section 43
Where, in a scheme of amalgamation, any capital asset is transferred by the amalgamating company
to the amalgamated company (being an Indian company), the actual cost of the transferred capital
asset to the amalgamated company shall be taken to be the same as it would have been if the
amalgamating company had continued to hold the capital asset for the purposes of its own business.
Section 43C
Where an asset [not being an asset referred to in sub-section (2) of section 45] which becomes the
property of an amalgamated company under a scheme of amalgamation, is sold by the amalgamated
company as stock-in-trade of the business carried on by it, the cost of acquisition of the said asset to
the amalgamated company in computing the profits and gains from the sale of such asset shall be
the cost of acquisition of the said asset to the amalgamating company, as increased by the cost, if
any, of any improvement made thereto, and the expenditure, if any, incurred, wholly and exclusively
in connection with such transfer by the amalgamating company.
Section 44DB
Provisions of the section regarding business reorganisation of co-operative banks include
amalgamation.
Section 47
Following transactions should be exempt from tax:-
(vi) any 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;]
[(via) any transfer, in a scheme of amalgamation, of a capital asset being a share or shares held in an
Indian company, by the amalgamating foreign company to the amalgamated foreign company, if
(a) at least twenty-five per cent of the shareholders of the amalgamating foreign company
continue to remain shareholders of the amalgamated foreign company, and
(b) such transfer does not attract tax on capital gains in the country, in which the
amalgamating company is incorporated;]
(viaa) any transfer, in a scheme of amalgamation of a banking company with a banking institution of
a capital asset by the banking company to the banking institution.
(vii) any transfer by a shareholder, in a scheme of amalgamation, of a capital asset being a share or
shares held by him in the amalgamating company, if
(a) the transfer is made in consideration of the allotment to him of any share or shares in the
amalgamated company except where the shareholder itself is the amalgamated company,
and
(b) the amalgamated company is an Indian company;
Section 72A
Amalgamation should be of
A company owning an industrial undertaking or a ship or a hotel with another company.
Banking Company with Specified Bank.
PSUs engaged in business of operation of aircrafts.
Conditions to be satisfied by Amalgamating Company
The unabsorbed business loss are from the main activity of said company it is in business for
preceding 3 or more years.
As on date of amalgamation, amalgamating company has held continuously 75% of the book
value of fixed assets held by it two years prior to the date of amalgamation.
Conditions to be satisfied by Amalgamating Company
The company should hold continuously for a minimum period of 5 years, atleast 75% of book
value of fixed assets.
The company should continue the business of amalgamating company for at least 5 years.
Any other conditions to be satisfied if required to ensure that amalgamation is for genuine
business purpose.
In case of non-compliance later, amount set off to be considered as income of that year.
Section 72AA
Where there has been an amalgamation of a banking company with any other banking institution,
the accumulated loss and the unabsorbed depreciation of such banking company shall be deemed to
be the loss or, as the case may be, allowance for depreciation of such banking institution for the
previous year in which the scheme of amalgamation was brought into force and other provisions of
this Act relating to set-off and carry forward of loss and allowance for depreciation shall apply
accordingly.
Section 72AB
Conditions to be satisfied by predecessor co-operative bank
Has been engaged in the business of banking for three or more years.
As on date of amalgamation, predecessor bank has held continuously 75% of the book value
of fixed assets held by it two years prior to the date of amalgamation.
Conditions to be satisfied by successor co-operative bank
The bank should hold continuously for a minimum period of 5 years, atleast 75% of book
value of fixed assets.
The bank should continue the business of predecessor bank for at least 5 years.
Any other conditions to be satisfied if required to ensure that amalgamation is for genuine
business purpose.
In case of non-compliance later, amount set off to be considered as income of that year.


Section 79
There shall be no carry forward and set off of losses allowed to the company unless on the last day
of the previous year, beneficial shareholders holding shares not less than 51% of the voting power in
the closely held company in which such loss occur becomes the beneficial shareholders holding
shares of 51% of the voting power of other company.
If there is any change in the shareholding of an Indian company which is a subsidiary of a foreign
company as a result of amalgamation of a foreign company subject to the condition that fifty-one
per cent shareholders of the amalgamating or demerged foreign company continue to be the
shareholders of the amalgamated foreign company, then the provisions of this section shall not
apply.
Section 80IA
Where any undertaking of an Indian company which is entitled to the deduction under this section
regarding tax benefits on the profits or gain derived from the business of the undertaking of eligible
business is transferred before the expiry of the period specified in this section and before 1
st
April,
2007, shall, as far as may be, apply to the amalgamated company as they would have applied to the
amalgamating company if the amalgamation had not taken place.
Section 80IB
Where any undertaking of an Indian company which is entitled to the deduction under this section
regarding tax benefits on the profits or gain derived from the business of the undertaking of eligible
business is transferred before the expiry of the period specified in this section, shall, as far as may
be, apply to the amalgamated company as they would have applied to the amalgamating company if
the amalgamation had not taken place.















DEMERGER
Section No Section Heading
2 Definitions
10A Special provision in respect of newly established undertakings in free trade zone, etc
10AA Special provisions in respect of newly established Units in Special Economic Zones
10B
Special provisions in respect of newly established hundred per cent export-oriented
undertakings
32 Depreciation
32AC Investment in new plant or machinery
35A Expenditure on acquisition of patent rights or copyrights
35AB Expenditure on know-how
35ABB Expenditure for obtaining licence to operate telecommunication services
35D Amortisation of certain preliminary expenses
35DDA Amortisation of expenditure incurred under voluntary retirement scheme
35E Deduction for expenditure on prospecting, etc., for certain minerals
42
Special provision for deductions in the case of business for prospecting, etc., for mineral
oil
43
Definitions of certain terms relevant to income from profits and gains of business or
profession
44DB
Special provision for computing deductions in the case of business reorganization of co-
operative banks
47 Transactions not regarded as transfer
49 Cost with reference to certain modes of acquisition
72A
Provisions relating to carry forward and set off of accumulated loss and unabsorbed
depreciation allowance in amalgamation or demerger, etc
72AB
Provisions relating to carry forward and set off of accumulated loss and unabsorbed
depreciation allowance in business reorganisation of co-operative banks
79 Carry forward and set off of losses in the case of certain companies
80-IA
Deductions in respect of profits and gains from industrial undertakings or enterprises
engaged in infrastructure development, etc.
80-IB
Deduction in respect of profits and gains from certain industrial undertakings other
than infrastructure development undertakings
115AC
Tax on income from bonds or Global Depository Receipts purchased in foreign
currency or capital gains arising from their transfer.
115VZ Demerger.









Section 2
[2] An arrangement is said to be a demerger when:
All the properties and liabilities of the undertaking are transferred.
The properties and liabilities are transferred at book value.
Shareholders holing not more than 3/4th in value of shares in the amalgamating company(s)
become shareholder of the amalgamated company.
Consideration is discharged by issue of shares.
The transfer of the undertaking in on the going concern basis.
[22] Dividend does not include any distribution of shares pursuant to a demerger by the resulting
company to the shareholders of the demerged company (whether or not there is a reduction of
capital in the demerged company).
[42A] In the case of a capital asset, being a share or shares in an Indian company, which becomes the
property of the assessee in consideration of a demerger, there shall be included the period for which
the share or shares held in the demerged company were held by the assessee.
Section 10A
Where any undertaking of an Indian company which is entitled to the deduction under this section
regarding deduction of profits of article or thing or computer software is transferred, before the
expiry of the period specified in this section, to another Indian company in a scheme of demerger,
the provisions of this section shall, as far as may be, apply to the resulting company as they would
have applied to the demerged company if the demerger had not taken place.
Section 10AA
Where any undertaking of an Indian company which is entitled to the deduction under this section
regarding deduction of profits from manufacturing or producing articles or things or providing any
services during the previous year relevant to the assessment year is transferred, before the expiry of
the period specified in this section, to another Indian company in a scheme of demerger, the
provisions of this section shall, as far as may be, apply to the resulting company as they would have
applied to the demerged company if the demerger had not taken place.
Section 10B
Where any undertaking of an Indian company which is entitled to the deduction under this section
regarding deduction of profits derived by a hundred per cent export-oriented undertaking from the
export of articles or things or computer software during the previous year relevant to the
assessment year is transferred, before the expiry of the period specified in this section, to another
Indian company in a scheme of demerger, the provisions of this section shall, as far as may be, apply
to the resulting company as they would have applied to the demerged company if the demerger had
not taken place.
Section 32
(1) Aggregate deduction in respect of depreciation of tangible and intangible assets allowed to the
demerged company or the resulting company in the case of demerger shall not exceed the amount
calculated as if the succession or demerger has not taken place.
In this section, "sold" includes a transfer by way of exchange or a compulsory acquisition but does
not include a transfer, in a scheme of amalgamation, of any asset by the amalgamating company to
the amalgamated company where the amalgamated company is an Indian company or in the
scheme of amalgamation of a banking company.
Section 32AC
Any allowance received under this section regarding deduction of amount on capital asset for
production of article or thing will be reversed if the new asset acquired and installed by the assessee
is sold within a period of five years from the date of installation and is applicable in case of demerger
also.
Section 35A
(6) Where, in a scheme of demerger, the demerged company sells or otherwise transfers the rights
so acquired to the resulting company (being an Indian company), the provisions of this section shall,
as far as may be, apply to the resulting company as they would have applied to the demerged
company if the demerger had not taken place.
Section 35AB
(3) Where there is a transfer of an undertaking under a scheme of demerger and the demerged
company is entitled to a deduction under this section regarding expenditure on know-how, then, the
resulting company, as the case may be, shall be entitled to claim deduction under this section in
respect of such undertaking to the same extent and in respect of the residual period as it would have
been allowable to the demerged company, as the case may be, had such demerger not taken place.
Section 35ABB
(6) Where, in a scheme of demerger, the demerged company sells or otherwise transfers the licence
to the resulting company (being an Indian company), the provisions of this section shall, as far as
may be, apply to the resulting company as they would have applied to the demerged company if the
amalgamation had not taken place.
Section 35D
Where the undertaking of an Indian company which is entitled to the deduction under this section
for preliminary expenses is transferred to another Indian company in a scheme of demerger, the
provisions of this section shall, as far as may be, apply to the resulting company as they would have
applied to the demerged company if the demerger had not taken place.
Section 35DDA
Where the assessee, being an Indian company, is entitled to the deduction under this section
regarding amortisation of expenditure incurred under VRS and the undertaking of such Indian
company entitled to the deduction under this section is transferred to another Indian company in a
scheme of demerger, the provisions of this section shall, as far as may be, apply to the resulting
company as they would have applied to the demerged company if the demerger had not taken
place.
However, no deduction shall be allowed to the resulting company for the previous year in which
demerger as the case may be, takes place.
Section 35E
Where the undertaking of an Indian company which is entitled to the deduction under this section
regarding deduction for expenditure on prospecting, etc., for certain minerals is transferred to
another Indian company in a scheme of demerger, the provisions of this section shall, as far as may
be, apply to the resulting company as they would have applied to the demerged company if the
demerger had not taken place.

Section 42
Where in a scheme of demerger, the demerged company sells or otherwise transfers the business to
the resulting company (being an Indian company), the provisions of this section shall, as far as may
be, apply to the resulting company as they would have applied to the demerged company if the
demerger had not taken place.
Section 43
Where, in a scheme of demerger, any capital asset is transferred by the demerged company to the
resulting company (being an Indian company), the actual cost of the transferred capital asset to the
resulting company shall be taken to be the same as it would have been if the demerged company
had continued to hold the capital asset for the purposes of its own business.
Section 44DB
Provisions of the section regarding business reorganisation of co-operative banks include demerger.
Section 47
Following transactions should be exempt from tax:-
(vib) any transfer, in a demerger, of a capital asset by the demerged company to the resulting
company, if the resulting company is an Indian company;
(vic) any transfer in a demerger, of a capital asset, being a share or shares held in an Indian
company, by the demerged foreign company to the resulting foreign company, if
(a) the shareholders holding not less than three-fourths in value of the shares of the
demerged foreign company continue to remain shareholders of the resulting foreign
company; and
(b) such transfer does not attract tax on capital gains in the country, in which the demerged
foreign company is incorporated
(vid) Any transfer or issue of shares by the resulting company, in a scheme of demerger to the
shareholders of the demerged company if the transfer or issue is made in consideration of demerger
of the undertaking
Section 72A
[4] In the case of a demerger, the accumulated loss and the allowance for unabsorbed depreciation
of the demerged company shall
(a) where such loss or unabsorbed depreciation is directly relatable to the undertakings
transferred to the resulting company, be allowed to be carried forward and set off in the
hands of the resulting company;
(b) where such loss or unabsorbed depreciation is not directly relatable to the undertakings
transferred to the resulting company, be apportioned between the demerged company and
the resulting company in the same proportion in which the assets of the undertakings have
been retained by the demerged company and transferred to the resulting company, and be
allowed to be carried forward and set off in the hands of the demerged company or the
resulting company, as the case may be.

Section 72AB
(3) The amount of set-off of the accumulated loss and unabsorbed depreciation, if any, allowable to
the assessee being a resulting co-operative bank shall be,
(i) the accumulated loss or unabsorbed depreciation of the demerged co-operative bank if
the whole of the amount of such loss or unabsorbed depreciation is directly relatable to the
undertakings transferred to the resulting co-operative bank; or
(ii) the amount which bears the same proportion to the accumulated loss or unabsorbed
depreciation of the demerged co-operative bank as the assets of the undertaking
transferred to the resulting co-operative bank bears to the assets of the demerged co-
operative bank if such accumulated loss or unabsorbed depreciation is not directly relatable
to the undertakings transferred to the resulting co-operative bank.
Section 79
There shall be no carry forward and set off of losses allowed to the company unless on the last day
of the previous year, beneficial shareholders holding shares not less than 51% of the voting power in
the closely held company in which such loss occur becomes the beneficial shareholders holding
shares of 51% of the voting power of other company.
If there is a change in the shareholding of an Indian company which is a subsidiary of a foreign
company as a result of demerger of a foreign company subject to the condition that fifty-one per
cent shareholders of the demerged foreign company continue to be the shareholders of the
resulting foreign company, then the provisions of this section shall not apply.
Section 80IA
Where any undertaking of an Indian company which is entitled to the deduction under this section
regarding tax benefits on the profits or gain derived from the business of the undertaking of eligible
business is transferred before the expiry of the period specified in this section and before 1
st
April,
2007, shall, as far as may be, apply to the resulting company as they would have applied to the
demerged company if the demerger had not taken place.
Section 80IB
Where any undertaking of an Indian company which is entitled to the deduction under this section
regarding tax benefits on the profits or gain derived from the business of the undertaking of eligible
business is transferred before the expiry of the period specified in this section, shall, as far as may
be, apply to the resulting company as they would have applied to the demerged company if the
demerger had not taken place.







SLUMP SALE
Section 2(42C)
"slump sale" means the transfer of one or more undertakings as a result of the sale for a lump sum
consideration without values being assigned to the individual assets and liabilities in such sales.
Section 50B
Any profits or gains arising from the slump sale affected in the previous year shall be chargeable to
income-tax as capital gains arising from the transfer of long-term capital assets and shall be deemed
to be the income of the previous year in which the transfer took place
Capital gain from undertaking held for not more than thirty-six months immediately preceding the
date of its transfer shall be deemed to be the capital gains arising from the transfer of short-term
capital assets.
Every assessee, in the case of slump sale, shall furnish a report indicating the computation of the net
worth of the undertaking or division
"net worth" shall be the aggregate value of total assets of the undertaking or division as
reduced by the value of liabilities of such undertaking or division as appearing in its books of
account :
revaluation of assets shall be ignored
the aggregate value of total assets shall be,
(a) in the case of depreciable assets, the written down value of the block of assets
(b) in the case of capital assets in respect of which the whole of the expenditure has been
allowed or is allowable as a deduction under section 35AD, nil; and
(c) in the case of other assets, the book value of such assets