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Case lawCBDT Circulars & Instructions › Statutory position — s.2(19AA): the seven conditions of a "demerger", the going-concern requirement, transfer at book value and the Indian Accounting Standards proviso
CBDT Circulars & InstructionsCuts both wayss.2(19AA)s.2(1B)s.45s.47(vib)s.47(vic)s.47(vicc)s.47(vid)s.72A(4)s.72A(5)

Statutory position — s.2(19AA): the seven conditions of a "demerger", the going-concern requirement, transfer at book value and the Indian Accounting Standards proviso

We hived off a division under a court-sanctioned scheme and claimed section 47(vib) and section 72A(4). The Assessing Officer says it is not a "demerger". What exactly does section 2(19AA) require, and what is the position where Ind AS forced us to record the assets at a different value?

We hived off a division under a court-sanctioned scheme and claimed section 47(vib) and section 72A(4). The Assessing Officer says it is not a "demerger". What exactly does section 2(19AA) require, and what is the position where Ind AS forced us to record the assets at a different value?

Section 2(19AA) requires a transfer pursuant to a scheme of arrangement under sections 391 to 394 of the Companies Act, 1956, by a demerged company of one or more of its undertakings to a resulting company, AND seven further conditions: all the property of the undertaking passes; all the liabilities relatable to it pass; the property and liabilities are transferred at values appearing in the demerged company's books immediately before the demerger; the resulting company issues its shares to the demerged company's shareholders on a proportionate basis; shareholders holding not less than three-fourths in value of the shares of the demerged company become shareholders of the resulting company; the transfer of the undertaking is on a going-concern basis; and the demerger accords with any conditions notified under s.72A(5). The book-value condition now carries a proviso which disapplies it where the resulting company records a different value in compliance with the Indian Accounting Standards specified in the Annexure to the Companies (Indian Accounting Standards) Rules, 2015.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2020-04-01, reported as Income-tax Act, 1961, s.2(19AA), as printed on the departmental Year 2025 page, with the proviso to sub-clause (iii) inserted by Act No. 23 of 2019 w.e.f. 1 April 2020. It bears on section 2(19AA), section 2(1B), section 45, section 47(vib), section 47(vic), section 47(vicc), section 47(vid), section 72A(4), section 72A(5) of the Income Tax Act 1961, in Capital Gains, Capital Gains Exemptions and How Tax Law Is Read matters.

Still good law. The Year 2025 departmental page is the most recent edition of s.2 I could reach this pass, and its text is corroborated for every sub-clause and Explanation by the Year 2018 page, which differs only in lacking the proviso to sub-clause (iii) that the Year 2019 (No. 2) page records as inserted by Act No. 23 of 2019 w.e.f. 1 April 2020. No Finance Act text was read this pass, and I did not check judicial treatment of s.2(19AA) generally. The reference in the opening words to sections 391 to 394 of the Companies Act, 1956 is reproduced as printed and its operation after the Companies Act, 2013 is not addressed.

Why it matters

Unlike "amalgamation", the demerger definition does require a scheme of arrangement — but the scheme is only the gateway, and practitioners routinely stop there. The conditions that actually decide cases are the ones a scheme draftsman controls only imperfectly. "All the liabilities relatable to the undertaking" is expanded by Explanation 2 to include liabilities arising out of the activities or operations of the undertaking, specific loans or borrowings raised, incurred and utilised solely for it, and a proportionate slice of general or multipurpose borrowings computed on the ratio the value of the transferred assets bears to the total assets of the demerged company immediately before the demerger — so a scheme that transfers assets but leaves general borrowings entirely behind is exposed. "Undertaking" is defined in Explanation 1 to include any part of an undertaking, or a unit or division, or a business activity taken as a whole, but expressly NOT individual assets or liabilities or any combination of them not constituting a business activity: a bare asset transfer wrapped in a scheme is not a demerger. Explanation 3 tells you that in testing the book-value condition any change in the value of assets consequent to their revaluation is to be ignored — the revaluation is stripped out, not honoured. The Ind AS proviso is a genuine relief and is often missed: where the resulting company must record a different value to comply with Ind AS, the book-value condition does not apply. Explanations 4 and 5 create two deeming routes — the splitting up or reconstruction of a statutory authority, local authority or public sector company, and of a company that ceased to be a public sector company on a transfer of its shares by the Central Government — but both are conditional on the Central Government notifying conditions, so neither is self-executing. Note carefully that the printed text still refers to sections 391 to 394 of the Companies Act, 1956; those sections have been replaced in the companies-law scheme by the Companies Act, 2013, and the effect of that on the tax definition is a live question this entry does not answer. There is now a decided case on the point that these conditions are cumulative and mandatory, and it went against the taxpayer: in Avaya Global Connect Ltd. v. ACIT Range 7(3) (ITAT Mumbai, 29 July 2008, assessment year 2002-03) the Tribunal held at para 19 that "All the conditions laid down in Section 2(19AA) have to be satisfied in a case to be called a demerger for the purpose of Section 47(vib) of the Act", rejected the argument that sub-clauses (iv) and (v) apply only where there is consideration for the transfer, and held that the transfer before it "cannot be regarded as a 'demerger' within the meaning of Section 2(19AA) of the Act".

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