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Person liable under Sec 47A


10 February 2011 Under Sec47A of IT Act, capital gain on transfer between Holding & subidiary which were exempt under Sec 47 would become taxable under certain circumstances and it is chargeable in the year of such occurrance.

The question is who is liable for tax payment - Transferor or Transferree?

If it is transferor (assuming- holding co)and such holding co was aquired by another company, who will be held liable?

11 February 2011 Transferor has to pay the tax in all cases .

If holding compnay is acquired by others, other will pay the tax liability.

12 February 2011 Sir
Is there any Case Law to this view


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