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of <h1>Section 47(vib): Transfer of Capital Asset During Demerger Not Considered Transfer if Resulting Company is Indian Entity.</h1> Section 47(vib) of the Income Tax Act addresses the transfer of a capital asset during a demerger from a demerged company to a resulting company, stipulating that such a transaction is not considered a transfer if the resulting company is an Indian entity. The cost of the asset in the hands of the transferee is deemed to be the cost to the previous owner, i.e., the demerged company. Additionally, the period of holding (POH) for the transferee includes the period for which the asset was held by the previous owner.
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