Amalgamation share transfer exemption: shareholder continuity and foreign tax neutrality prevent recognition of capital gains. Section 47(via) exempts from being treated as a transfer the movement of shares in an Indian company by an amalgamating foreign company to the amalgamated foreign company under an amalgamation, provided there is shareholder continuity between the two foreign companies and the transaction is not taxed as capital gains in the amalgamating company's country of incorporation. The transferee's cost is the cost to the previous owner and the previous owner's period of holding is taken into account for the transferee's holding period.