Capital gains exemption expands for foreign company restructurings and mutual fund scheme consolidation under amended transfer rules. Section 47 is amended to expand exempt transfer provisions for amalgamation, demerger, and mutual fund consolidation. The amendment covers transfers of shares of a foreign company deriving substantial value from shares of an Indian company, subject to shareholder-continuity conditions and the requirement that the transfer not attract capital gains tax in the country of incorporation. It also exempts unit transfers in mutual fund scheme consolidation, subject to specified scheme-merge conditions and defined terms.
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Provisions expressly mentioned in the judgment/order text.
Capital gains exemption expands for foreign company restructurings and mutual fund scheme consolidation under amended transfer rules.
Section 47 is amended to expand exempt transfer provisions for amalgamation, demerger, and mutual fund consolidation. The amendment covers transfers of shares of a foreign company deriving substantial value from shares of an Indian company, subject to shareholder-continuity conditions and the requirement that the transfer not attract capital gains tax in the country of incorporation. It also exempts unit transfers in mutual fund scheme consolidation, subject to specified scheme-merge conditions and defined terms.
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