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of <h1>Transfer of Capital Assets in Banking Mergers: Section 47(viaa) Exempts Transactions from Being Considered Transfers</h1> Section 47(viaa) of the Income Tax Act addresses the transfer of capital assets during the amalgamation of a banking company with a banking institution, as authorized by the Central Government under Section 45(7) of the Banking Regulation Act, 1949. Such transactions are not considered as transfers under Section 2(47). The capital asset involved is any held by the banking company, and the cost to the transferee is the cost to the previous owner, the banking company. The period of holding (POH) for the transferee includes the POH of the previous owner.
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