Non-transfer treatment for specified cross-border government securities transfers and SPV-to-business trust share exchanges removes capital transfer recognition. Two specific non-recognition exemptions were added: transfers of Government Securities made outside India through settlement intermediaries between non-residents are not treated as transfers for capital purposes, and transfers of shares of a Special Purpose Vehicle to a business trust in exchange for units allotted by that trust are not treated as transfers for capital purposes; statutory meanings for 'Government Security' and 'Special Purpose Vehicle' are adopted from existing legislative definitions.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Non-transfer treatment for specified cross-border government securities transfers and SPV-to-business trust share exchanges removes capital transfer recognition.
Two specific non-recognition exemptions were added: transfers of Government Securities made outside India through settlement intermediaries between non-residents are not treated as transfers for capital purposes, and transfers of shares of a Special Purpose Vehicle to a business trust in exchange for units allotted by that trust are not treated as transfers for capital purposes; statutory meanings for "Government Security" and "Special Purpose Vehicle" are adopted from existing legislative definitions.
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