VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.47(vi), (via), (vib), (vic), (vicc), (vid) and (vii): the amalgamation and demerger transfers that are not transfers, with the cost rules in s.49(2), (2C) and (2D)
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.47s.47(vi)s.47(via)s.47(vib)s.47(vic)s.47(vicc)s.47(vid)s.47(vii)s.49s.49(2)s.49(2C)s.49(2D)s.2(42A)s.2(1B)s.2(19AA)s.45s.47A

Statutory position — s.47(vi), (via), (vib), (vic), (vicc), (vid) and (vii): the amalgamation and demerger transfers that are not transfers, with the cost rules in s.49(2), (2C) and (2D)

Which transfers in an amalgamation or a demerger are outside section 45, and what cost and holding period do the shares in the transferee company carry afterwards?

Which transfers in an amalgamation or a demerger are outside section 45, and what cost and holding period do the shares in the transferee company carry afterwards?

Seven clauses of section 47 take reorganisation transfers out of section 45. At company level: (vi) a transfer in a scheme of amalgamation of a capital asset by the amalgamating company to the amalgamated company, if the amalgamated company is an Indian company; (vib) a transfer in a demerger of a capital asset by the demerged company to the resulting company, if the resulting company is an Indian company; (via) a transfer in a scheme of amalgamation of shares held in an Indian company by an amalgamating foreign company to an amalgamated foreign company, on two conditions; and (vic) and (vicc), the corresponding foreign demerger cases. At shareholder level: (vid) any transfer or issue of shares by the resulting company in a demerger to the shareholders of the demerged company in consideration of the demerger; and (vii) a transfer by a shareholder in a scheme of amalgamation of shares in the amalgamating company, if made in consideration of the allotment of shares in the amalgamated company except where the shareholder is itself the amalgamated company, and the amalgamated company is an Indian company. Clause (vi) is the central one: any transfer, in a scheme of amalgamation, of a capital asset by the amalgamating company to the amalgamated company, if the amalgamated company is an Indian company — this is what takes the transfer of the undertaking itself out of section 45. On cost, s.49(2) gives the shareholder who receives shares in an amalgamated Indian company on a s.47(vii) transfer the cost of his shares in the amalgamating company; s.49(2C) splits the cost of the demerged company's shares to the resulting company's shares in the ratio the net book value of the assets transferred bears to the net worth of the demerged company immediately before the demerger; and s.49(2D) reduces the cost of the original shares by the amount so arrived at.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2025-04-01, reported as Income-tax Act, 1961, s.47 and s.49, as printed on the departmental Year 2025 pages; s.2(42A) Explanation 1(i)(g) as printed on the Year 2024 (No. 1) page. It bears on section 47, section 47(vi), section 47(via), section 47(vib), section 47(vic), section 47(vicc), section 47(vid), section 47(vii), section 49, section 49(2), section 49(2C), section 49(2D), section 2(42A), section 2(1B), section 2(19AA), section 45, section 47A of the Income Tax Act 1961, in Capital Gains, Capital Gains Exemptions and How Tax Law Is Read matters.

Validity check could not be completed. Validity check could not be completed. Section 47 clauses (vi) to (vii) are now corroborated word for word on a second year-stamped departmental edition, /w/section-47-63 (Year: 2024 (No. 2)), obtained on verification. Section 49(2), (2C) and (2D) still rest on a single edition, /w/section-49-64 (Year: 2025), and no footnote apparatus was read for either section, so no amending Act or commencement date is stated for any clause. A later pass should obtain a second edition for section 49 and should retrieve the holding-period paragraph for shares received in an amalgamation, which was not reached. No check of judicial treatment was carried out; the library already holds CIT v Grace Collis on s.47(vii) and s.49(2), Reckitt Benckiser Healthcare India on s.47(vib) and (vid), and DCIT v Cyquator Media Services on s.47(vi).

Why it matters

A reader who gets the exemption right and the cost wrong is no better off, and the two errors are made at opposite ends of the file. Four traps sit in this material. First, the words in clause (vii) "except where the shareholder itself is the amalgamated company": in an upstream merger of a subsidiary into its parent, the parent's own shares in the subsidiary are outside the clause, and the parent's gain or loss on extinguishment is not sheltered by clause (vii). Second, clauses (vib), (vid) and (vii) all require the transferee to be an Indian company or, for clause (vid), operate only on an issue or transfer by the resulting company in consideration of the demerger — a cash element or a debt instrument is outside them. Third, clauses (vic) and (vicc) each carry a proviso in the same words, that "the provisions of sections 391 to 394 of the Companies Act, 1956 (1 of 1956) shall not apply in case of demergers referred to in this clause" — that is a deliberate disapplication for the foreign demerger cases and it is easy to misread as the opposite. Fourth, and most often missed, clause (via) sets the shareholder continuity threshold at TWENTY-FIVE per cent for the foreign amalgamation case, not three-fourths, while clauses (vic) and (vicc) use three-fourths for the foreign demerger cases. On the arithmetic afterwards, s.49(2C) is a proportion of COST, computed on a ratio of net book value of assets transferred to net worth of the demerged company immediately before the demerger, and s.49(2D) is a matching reduction — the two must be applied together or the shareholder double counts. For holding period, Explanation 1(i)(g) to s.2(42A) includes, for shares in an Indian company received in consideration of a demerger, the period for which the shares in the demerged company were held. The condition precedent is not academic. In Avaya Global Connect Ltd. v. ACIT Range 7(3) (ITAT Mumbai, 29 July 2008) 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", refused to read sub-clauses (iv) and (v) as inapplicable where there was no consideration, and held the transfer before it was not a demerger — so section 47(vib) was unavailable and the gain was chargeable.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

Read aloud by your device. Press again to stop.

Related

Other authorities on the same sections.