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Section 47(vic) - Transfer of shares held in an Indian company by a demerged foreign company to the resulting foreign company - Income Tax - Ready Reckoner - Income TaxExtract Section 47(vic) :- Transfer of shares held in an Indian company by a demerged foreign company to the resulting foreign company Section Transaction not regarded as transfer Transferor u/s 2(47) Transferee u/s 2(47) Capital asset involved u/s 2(14) What is the cost in the hands of transferee Period of holding 47(vic) Transfer in a scheme of demerger, where in such transfer does not attract Capital Gains in the Country of incorporation of demerged foreign company Demerged Foreign Company Resulting Foreign company Shares of Indian company (domestic company) Value by which the original cost of acquisition of shares in the demerged company exceeds cost of acquisition of shares of the resulting company - NOTE:- Persons holding atleast 75% in value of shares in the demerged foreign company should become shareholders in the resulting foreign company. The transaction does not attract tax on capital gains in the country in which the demerged company is incorporated.
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