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<h1>Transfer of SPV Shares to Business Trust Exempt from Capital Gains under Section 47(xvii) of Income Tax Act</h1> Section 47(xvii) of the Income Tax Act addresses the transfer of shares from a Special Purpose Vehicle (SPV) to a business trust. Such a transaction is not considered a transfer for capital gains purposes. The cost of acquisition (COA) for the business trust units received by the SPV shareholder is equivalent to the cost at which the shares were originally acquired in the SPV. Additionally, the holding period of the shares by the previous owner in the SPV is included when the transferee subsequently transfers the asset.