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<h1>Transfer not regarded as transfer: amalgamation of foreign companies' shares deriving value from Indian company avoids capital gains recognition.</h1> Non-recognition applies where a share of a foreign company transferred in a scheme of amalgamation between foreign resident companies derives substantially its value from shares of an Indian company; the transfer is not a 'transfer' for capital gains purposes, the transferee inherits the cost of the previous owner, and the previous owner's period of holding is considered.