Intercompany transfer rule clarified: reciprocal transfers between holding and subsidiary qualify when corresponding tax-neutral conditions are met. The Explanation to clause (i) of subsection (2) of section 34 is revised to treat transfers made either by a holding company to its subsidiary or by a subsidiary to its holding company as qualifying for the special transfer rule, provided the relevant conditions in the corresponding provisions of the Act governing tax-neutral transfers are satisfied.
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Intercompany transfer rule clarified: reciprocal transfers between holding and subsidiary qualify when corresponding tax-neutral conditions are met.
The Explanation to clause (i) of subsection (2) of section 34 is revised to treat transfers made either by a holding company to its subsidiary or by a subsidiary to its holding company as qualifying for the special transfer rule, provided the relevant conditions in the corresponding provisions of the Act governing tax-neutral transfers are satisfied.
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