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of <h1>Section 47: Transactions excluded from capital gains tax-gifts, partitions, amalgamations, restructurings, conversions, and specified institutional transfers</h1> Section 47 specifies numerous transactions that are not treated as 'transfer' for capital gains tax purposes, including distributions on partition of a Hindu undivided family; transfers by way of gift, will or irrevocable trust by individuals/HUFs; transfers between parent and wholly-owned subsidiary or vice versa; transfers in schemes of amalgamation, demerger, business reorganisation, relocation of certain foreign funds, conversions (e.g., bonds to shares, preference to equity), succession of firms or proprietary concerns by companies, conversion of companies into LLPs subject to conditions, securities lending under prescribed guidelines, certain non-resident to non-resident transfers in prescribed markets or instruments, mutual fund scheme/plan consolidations, and specified transfers involving government, banking and public sector entities. These transactions are excluded from capital gains levy when statutory conditions are met.
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