Tax Treatment of Losses in Demergers: Does Partial Asset Transfer Qualify u/s 2(19AA) of Income Tax Act?

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....Carry forward and set-off of losses - demerger - Applicability of provisions of Sec. 72A(4) - transfer of only the specified assets and liabilities - the scheme of arrangement in question does not qualify to be a ‘demerger’ in terms of section 2(19AA) - AT....