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Withdrawal of exemption in certain cases.
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....ad "Capital gains" of the tax year in which such transfer took place, if at any time before the expiry of eight years from the date of such transfer,- (a) the transferee company converts the capital asset into, or treats it as, stock-in-trade of its business; or (b) the parent company or its nominees or the holding company, ceases or cease to hold the whole of the share capital of the subsidia....