Amendment to asset transfer taxation: excludes transfer treatment when the shareholder itself is the amalgamated company. Amendment revises clause (vii)(a) of section 47 to create an exception where the shareholder is itself the amalgamated company, narrowing the prior treatment of transfers to an amalgamated company so that the specified tax consequence does not apply when the transferee and the transferring shareholder are the same corporate entity.
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Provisions expressly mentioned in the judgment/order text.
Amendment to asset transfer taxation: excludes transfer treatment when the shareholder itself is the amalgamated company.
Amendment revises clause (vii)(a) of section 47 to create an exception where the shareholder is itself the amalgamated company, narrowing the prior treatment of transfers to an amalgamated company so that the specified tax consequence does not apply when the transferee and the transferring shareholder are the same corporate entity.
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