Demerger transfer exemption: specified capital asset and share transfers treated as tax neutral subject to continuity and jurisdictional conditions. Amendment inserts three demerger-related exceptions into section 47: tax-neutral treatment for capital asset transfers from a demerged company to a resulting Indian company; tax-neutral treatment for share transfers between demerged and resulting foreign companies subject to at least 75% shareholder continuity and non-recognition of capital gains in the country of incorporation, with specified reorganisation provisions not applying; and tax-neutral treatment for transfer or issue of shares by the resulting company to shareholders as consideration for the demerger.
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Provisions expressly mentioned in the judgment/order text.
Demerger transfer exemption: specified capital asset and share transfers treated as tax neutral subject to continuity and jurisdictional conditions.
Amendment inserts three demerger-related exceptions into section 47: tax-neutral treatment for capital asset transfers from a demerged company to a resulting Indian company; tax-neutral treatment for share transfers between demerged and resulting foreign companies subject to at least 75% shareholder continuity and non-recognition of capital gains in the country of incorporation, with specified reorganisation provisions not applying; and tax-neutral treatment for transfer or issue of shares by the resulting company to shareholders as consideration for the demerger.
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