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    <title>2020 (12) TMI 288 - MADRAS HIGH COURT</title>
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    <description>Stamp duty exemption under G.O.Ms.No.1224 depended on satisfaction of entry 38, namely that at least 90% of the transferee company&#039;s issued share capital was beneficially owned by the transferor company. The materials showed more than 99% ownership at the time of transfer, so the substantive eligibility condition was met. The proviso was treated as a mode of proof, not an additional substantive requirement mandating records from the Registrar of Companies, Madras. Certified corporate records from Mumbai were accepted as sufficient proof of substantial compliance, and the rejection of the exemption claim was held unsustainable.</description>
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