Transfer of a capital asset by a holding company to its 100% subsidiary company & vice versa - (New) Section 70(1)(c) & (d) / (Old) Section 47(iv) & 47(v)

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...., 2025 [ From 01.04.2026 ] Section Transaction not Regarded as Transfer What is the Cost in the Hand of Transferee Period of Holding Section 70(1)(c) Transfer of a capital asset, not being stock-in-trade, by a company to its subsidiary company, if- • (i) the parent company or its nominees hold the whole of the share capital of the subsidiary company; and ....

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....sferee company: • converts the capital asset into stock-in-trade; or • treats it as stock-in-trade of its business. (b) Wholly-owned relationship ceases The parent company, its nominees, or the holding company ceases to hold the entire share capital of the subsidiary. Tax Consequence of Violation • The original transfer becomes taxable retrospectivel....

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.... of previous owner shall also be considered. Section 47A : Withdrawal of Exemption :- Section 47(iv) and Section 47(v) grant a tax-neutral treatment to transfers of capital assets between a holding company and its wholly-owned Indian subsidiary (and vice versa). Such transfers are not regarded as "transfers" for capital gains purposes. The exemption is withdrawn if, within 8 years from th....