Mutual fund unit consolidation: tax-free exchange where consolidating units are allotted consolidated units if plan types match under Section 47(xix) Section 47(xix) provides that surrender of units in a consolidating plan in consideration of allotment of units in the consolidated plan of the same mutual fund scheme is not a transfer for capital gains purposes. The exemption applies only where the consolidation is between plans of the same orientation (equity with equity or debt with debt) and where the mutual fund qualifies under the statutory description applicable to mutual funds.