Amendment of section 47.

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.... the shareholders of the amalgamating foreign company continue to remain shareholders of the amalgamated foreign company; and (B) such transfer does not attract tax on capital gains in the country in which the amalgamating company is incorporated;"; (b) after clause (vicb), the following clause shall be inserted, namely:- "(vicc) any transfer in a demerger, of a capital asset, being a share of a foreign company, referred to in Explanation 5 to clause (i) of sub-section (1) of section 9, which derives, directly or indirectly, its value substantially from the share or shares of an Indian company, held by the demerged foreign company to the resulting foreign company, if,- (a) the shareholders, holding not less than three-fourths in....

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....e (38) of section 10; (d) "mutual fund" means a mutual fund specified under clause (23D) of clause 10.'. - Clause 13 of the Bill seeks to amend section 47 of the Income tax Act relating to transactions not regarded as transfer. The existing provisions contained in section 47 of the Act provide that capital gains are not applicable to the transfers specified in the said section. Clause (via) of the said section provides that transfer of capital asset being shares of an Indian company by a foreign company to another foreign company under scheme of amalgamation shall not be treated as transfer subject to conditions provided in the said clause. Clause (vic) of the said section provides that transfer of capital asset being shares of a....