Amendment of section 47

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....eferred to in the 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 amalgamating foreign company to the amalgamated foreign company, if- (A) at least twenty-five per cent. of the shareholders of the amalgamating foreign company continue to remain shareholders of the....

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....s not attract tax on capital gains in the country in which the demerged foreign company is incorporated: Provided that the provisions of sections 391 to 394 of the Companies Act, 1956 (1 of 1956) shall not apply in case of demergers referred to in this clause;"; (c) after clause (xvii), the following clause shall be inserted, namely:- '(xviii) any transfer by a unit holder of a capital asset, b....