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<h1>Wholly owned subsidiary concept clarified: authority requires near-total parental shareholding for advance ruling purposes.</h1> The term wholly owned subsidiary is not defined in the Companies Act, 1956 or other statutes for advance rulings; because absolute 100% ownership is not feasible under the Companies Act, the Advance Ruling Authority applied a functional approach, requiring an overwhelming majority shareholding by the holding company-a near-total parental stake short of absolute totality-to treat an entity as a wholly owned subsidiary for advance ruling purposes.