Transactions not regarded as transfer.

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.... (f) by a shareholder, in a scheme of amalgamation, of a capital asset being a share or shares held in the amalgamating company, if- (i) the transfer is made in consideration of allotment of any share or shares in the amalgamated company, except when the shareholder itself is the amalgamated company; and (ii) the amalgamated company is an Indian company; (g) in a scheme of amalgamation, of a capital asset being a share or shares held in an Indian company, by the amalgamating foreign company to the amalgamated foreign company, if- (i) at least 25% of the shareholders of the amalgamating foreign company continue to remain shareholders of the amalgamated foreign company; and (ii) such transfer does not attract tax on capital gains in the country, in which the amalgamating company is incorporated; (h) in a scheme of amalgamation, of a capital asset, being a share of a foreign company, referred to in section 9(9)(a), 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- (i) at least 25% of....

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....ganisation, of capital asset being share or shares held in the predecessor co-operative bank, if the transfer is made in consideration of the allotment to the shareholder of share or shares in the successor co-operative bank or the converted banking company; (p) of a capital asset, being bonds or Global Depository Receipts as referred to in section 209(1), made outside India by a non-resident to another non-resident; (q) made outside India, of a capital asset, being rupee denominated bond of an Indian company issued outside India, by a non-resident to another non-resident; (r) of a capital asset made by a non-resident on a recognised stock exchange located in any International Financial Services Centre, where the consideration for such transaction is paid or payable in foreign currency, and such capital asset is- (i) bond or Global Depository Receipt referred to in section 209(1); or (ii) rupee denominated bond of an Indian company; or (iii) derivative; or (iv) such other securities as notified by the Central Government; (s) of a capital asset, being a Government security carrying a periodic payment of interest....

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....) all the assets and liabilities of the firm relating to the business immediately before the succession become the assets and liabilities of the company; (ii) all the partners of the firm, immediately before the succession, become the shareholders of the company in the same proportion in which their capital accounts stood in the books of the firm on the date of the succession; (iii) the partners of the firm do not receive any consideration or benefit, directly or indirectly, in any form or manner, other than by way of allotment of shares in the company; and (iv) the aggregate of the shareholding of the partners in the company is at least 50% of the total voting power and such shareholding remains the same for five years from the date of succession; (ze) of a capital asset or intangible asset by a private company or unlisted public company (herein referred to as the company) to a limited liability partnership or transfer of a share or shares held in the company by a shareholder as a result of conversion of the company into a limited liability partnership under the provisions of section 56 or 57 of the Limited Liability Partnership Act, 2008 (6 of ....

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....s in the company; (zg) in a scheme for lending of any securities under an agreement or arrangement, entered into by the assessee with the borrower of such securities and which is subject to the guidelines issued by the Securities and Exchange Board of India or the Reserve Bank of India; (zh) of a capital asset in a transaction of reverse mortgage under a scheme notified by the Central Government; (zi) of a capital asset, being share or shares of a special purpose vehicle to a business trust in exchange of units allotted by that trust to the transferor; (zj) of a capital asset, being a unit or units, held by a unit holder in the consolidating scheme of a mutual fund, in consideration of the allotment to the unit holder of a capital asset, being a unit or units, in the consolidated scheme of the mutual fund subject to the condition that the consolidation is of two or more schemes-- (i) of an equity-oriented fund; or (ii) of a fund other than equity-oriented fund; (zk) of a capital asset, being a unit or units, held by a unit holder in the consolidating plan of a mutual fund scheme, in consideration of the allotment to the....

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....is a resident; and (iv) fulfils other conditions as prescribed; (B) an investment vehicle, in which Abu Dhabi Investment Authority is the direct or indirect sole shareholder or unit holder or beneficiary or interest holder and such investment vehicle is wholly owned and controlled, directly or indirectly, by the Abu Dhabi Investment Authority or the Government of Abu Dhabi; or (C) a fund notified by the Central Government subject to conditions as specified; (b) "relocation" means transfer of assets of the original fund, or of its wholly owned special purpose vehicle, to a resultant fund on or before the 31st March, 2025, where consideration for such transfer is discharged in the form of share or unit or interest in the resulting fund to- (i) a shareholder or unit holder or interest holder of the original fund, in the same proportion in which the share or unit or interest was held by such shareholder or unit holder or interest holder in such original fund, in lieu of their shares or units or interests in the original fund; or (ii) the original fund, in the same proportion as referred to in sub-clause (i), in respect of which the share ....