shareholder of the amalgamating company would be entitled to claim exemption from the provisions of section 45 of the Act if the following conditions ... amalgamated company, received bonds, it was not entitled to claim exemption under section 47(vii) . The Tribunal took the view to the effect that there
their returns of income filed for the assessment year in
question, claimed exemption under Section 47(vii) of the I.T. Act in respect ... Officer treated the shares of JFAL as stock-in-
trade, denied the exemption under Section 47(vii) , and brought to tax the value
wholly owned subsidiary company and thus, they
are entitled for exemption from payment of capital gains tax in terms of
Section ... will come into operation against the
petitioner and automatically, the exemption granted, under Section
47(iv) of the Act, would have been withdrawn. Thereafter
wholly owned subsidiary company and thus, they are
entitled for exemption from payment of capital gains tax in terms of
Section ... petitioner and automatically, the exemption granted, under Section 47(iv)
of the Act, would have been withdrawn. Thereafter, by invoking Section
wholly owned subsidiary company and thus, they are
entitled for exemption from payment of capital gains tax in terms of
Section ... petitioner and automatically, the exemption granted, under Section 47(iv)
of the Act, would have been withdrawn. Thereafter, by invoking Section
trade and not as capital asset, it was not
entitled to exemption under Section 47(vii) of the Act. The statutory first
Appellate Authority ... since
the shares in question were stock-in-trade of the assessees, exemption under
Section 47(vii) is not available and thus the transaction
therefore, the assessee was not entitled to claim exemption under Section 47(ii) of the Act. Thereafter, the assessee preferred appeal before the Appellate Assistant ... transaction. It is, therefore, contended that the assessee is entitled to the exemption under Section 47(ii) of the Act. On the other hand
Cellular Operators Association Of ... vs Telecom Regulatory Authority Of India ... on 11 May, 2016
Equivalent
opinion that the assessee was entitled to an exemption under Section 47(iii) of the Act. In his view, the transaction amounted to a gift ... would not be liable to capital gains. The provision contemplates an exemption from capital gains tax only if there is a "gift
Commissioner Of Income-Tax, Gujarat-I vs Kartikey V. Sarabhai on 4 May, 1981
Equivalent