Demerger of foreign company shares treated as non-transfer when shareholder continuity exists and no foreign capital gains tax arises. Section 47(vicc) provides non-recognition of transfer where, in a demerger, the capital asset transferred is a share of a foreign company that derives substantially its value from shares of an Indian company, provided shareholders holding a substantial preponderance of value in the demerged foreign company become shareholders in the resulting foreign company and the transaction does not attract capital gains tax in the country of incorporation.