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21. He further pointed out that in respect of the transfer of assets by a parent company to its wholly owned subsidiary company, even under the Indian Stamp Act there has been an exemption by virtue of a notification and under Section 20 of the Gujarat Sales Tax Act, an exemption in respect of such transfer has been carved out. He, therefore, contended that there could not be any such nefarious object and no such nefarious object could ever be attributed in respect of the present transaction and hence the requirements of Section 269C(1)(a) can never be said to have been satisfied in the instant case.