Section 47(vicb) exempts share transfers during co-op bank reorganizations from capital gains tax.

Section 47(vicb) of the Income Tax Act specifies that a transfer by a shareholder during a business reorganization is not considered a transfer for capital gains purposes. This applies when a shareholder transfers shares held in a predecessor co-operative bank in exchange for shares allotted in a successor co-operative bank. The transaction involves the transfer of capital assets, specifically shares, and is not recognized as a transfer under sections 2(47) and 2(14) of the Income Tax Act. This provision facilitates seamless transitions during business reorganizations without triggering capital gains tax liabilities.