Certain transactions not regarded as Transfer preserve tax neutrality for corporate reorganisations and specified securities transfers. Section 47 lists transactions not regarded as transfer for capital gains, including distributions on liquidation, family partitions, gifts/wills/irrevocable trusts (with ESOP exceptions), inter company transfers between wholly held Indian parent and subsidiary, restructurings under amalgamation and demerger subject to continuity and non taxation conditions, specified non resident securities transfers on recognised IFSC exchanges, conversions of securities with cost and holding period continuity, conversions of business entities subject to prescribed conditions and reversal rules, and special exclusions covering sovereign gold instruments, electronic gold receipts, stock lending schemes and transfers to notified public institutions.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Certain transactions not regarded as Transfer preserve tax neutrality for corporate reorganisations and specified securities transfers.
Section 47 lists transactions not regarded as transfer for capital gains, including distributions on liquidation, family partitions, gifts/wills/irrevocable trusts (with ESOP exceptions), inter company transfers between wholly held Indian parent and subsidiary, restructurings under amalgamation and demerger subject to continuity and non taxation conditions, specified non resident securities transfers on recognised IFSC exchanges, conversions of securities with cost and holding period continuity, conversions of business entities subject to prescribed conditions and reversal rules, and special exclusions covering sovereign gold instruments, electronic gold receipts, stock lending schemes and transfers to notified public institutions.
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