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<h1>Section 47(viab) exempts capital gains tax on foreign company share transfers in certain amalgamations.</h1> Section 47(viab) of the Income Tax Act addresses the transfer of capital assets in an amalgamation scheme, specifically involving shares of a foreign company. Such transfers are not considered taxable events under capital gains if the foreign company's shares derive substantial value from shares of an Indian company. The cost of the asset for the transferee is based on the cost to the previous owner, and the holding period includes that of the previous owner. These transactions are exempt from capital gains tax in the country where the amalgamating company is incorporated.