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Complete list of certain transactions not regarded as Transfer - Section 47

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..... 04.2025 ] Except ESOP * Note : a) This clause shall not apply to transfer under gift or an irrevocable trust of share, debenture or warrants alloted by company to employee under ESOPs. b) As per sixth proviso to section 48 FMV on the date of transfer (date of GIFT or irrevocable trust) shall be treated as FVOC of such shares, debentures or warrants. * Section 47(iv) - Transfer of capital assets by holding to 100% subsidiary if subsidiary is Indian Company * Section 47(v) - Transfer of capital assets by 100% subsidiary to holding, if holding is Indian Company Transfer Under Amalgamation : * Section 47(vi) - Transfer in scheme of amalgamation if amalgamated company is Indian * Section 47(via) & (viab) - Transfer of Shares in Indi .....

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..... inated bond of an Indian Co. - By one NR to another NR, outside India. * Section 47(viib) - Govt. Securities periodic payment of interest - By one NR to another NR, outside India through an intermediary dealing in settlement of securities. * Section 47(viiab) - a) Bonds or GDR referred to in Section 115AC * b) Derivative * c) RDB of Indian Co. * d) Such other securities as may be notified by Central Government [ Notification No : 16/2020 ] * - Foreign currency denominated bond * - Foreign currency denominated equity share of a company * - Units of a Mutual Fund * - Units of a Business Trust * - Units of Alternative Investment Fund * - Bullion Depositary Receipt * by NR on a Recognised Stock Exchange located in any IF .....

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..... ship * (ii) Cost of Acquisition of Trading/clearing right shall be NIL. * Period of holding shall be reckoned from date of his membership in RSE. * Sec 47(xiiib) - Conversion of Unlisted Public Co./Private Co. into LLP, following conditions to be fulfilled :- * a) All assets & liabilities transfer to LLP. * b) All shareholder become partners and their capital contribution & PSR are in proportion of their shareholding. * c) Consideration to shareholders will be share in profit & capital. * d) Total Profit Sharing Ratio in LLP of shareholder should be atleast 50% during 5 years from the date of conversion. * e) No Amount is paid directly/indirectly to an partner from accumulated profit balance standing on conversion date for .....

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..... d Bond issued by RBI under Sovereign Gold Bond Scheme 2015, by way of redemption by the assessee being an Individual. * Section 47(viid) - any transfer of a capital asset, being conversion of gold into Electronic Gold Receipt issued by a Vault Manager, or conversion of Electronic Gold Receipt into gold. * Sovereign Gold Bond scheme, 2015 * This scheme of the government of India is intended to reduce the demand for physical gold and consequently, reduce the foreign exchange outflow due to import gold . The two-fold benefit or this scheme are: * The gold Bond would serve as a subsitute for physical gold and * The gold bond would provide security to the individual investor investing in gold for meeting their social obligation. * V .....

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..... l asset under reversed mortgage under a scheme made and notified by Central Government. * Section 47(xvii) - Transfer of share of SPV to a Business Trust in exchange of units of the Trust. * Section 47(vica) - Transfer of capital asset in a business reorganisation, by the predecessor co-operative bank to the successor co-operative, or to the converted banking company. * Section 47(vicb) - Transfer of share by a shareholder, in a business reorganisation, if the transfer is made in consideration of the allotment to him of any share or shares in the successor co-operative bank or to the converted banking company. * Section 47(viiac) - Any transfer, in a relocation of a capital asset by the original fund to the resulting fund. * Secti .....

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