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            Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

            Provisions expressly mentioned in the judgment/order text.

            <h1>Demerger of foreign company shares treated as non-transfer when shareholder continuity exists and no foreign capital gains tax arises.</h1> 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.

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