...purpose of computation of income under the Income Tax Act, 1961. It is further their case that the Respondent-Company acquired the shareholding of Ms/. Anandeya and, therefore, has violated the provisions of Section 47(xiii)(d...and no transfer of asset as envisaged in Section 45(1) of the Income Tax Act, can be stated to have taken place and, as such, even the provisions of Section 47(xiii)(d...) are in violation, it does not attract capital gains to the Respondent's subsidiary because Section 47(xiii) applies only to firm that are succeeded by the company by sale. But, however, it is the contention of the Petitioner that Section 2(47) of the Income Tax Act, 1961...