(1)The profits or gains arising from the transfer of capital asset not charged under section 67 by virtue of section 70(1)(c) and (d) shall, irrespective of anything contained in the said clauses, be deemed to be income chargeable under the head "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 subsidiary company.
