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<h1>Shares issued in demerger treated as non-transfer with cost basis as proportionate original acquisition cost.</h1> Section 47(vid) excludes from 'transfer' the issuance or transfer of resulting company shares to shareholders of the demerged company under a demerger. The demerged company is treated as transferor and the shareholders as transferees; the capital asset is the resulting company shares. The transferee's cost equals the proportionate cost of acquisition of the demerged company shares, and the period of holding includes the previous owner's holding period.