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(1) Notwithstanding anything contained
in the Income-tax Act, 1961 (43 of 1961) or any other enactment for the time being in force relating to
tax or income, profits or gains, the Company shall not be liable to pay income-tax or any other tax for
a period of five years computed from the appointed day in respect of any income, profits or gains
derived, or any amount received by the Company.
(2) The transfer and vesting of the undertakings or any part thereof in terms of section 3 shall not
be construed as a transfer within the meaning of the Income-tax At, 1961 (43 of 1961) for the purposes
of capital gains.
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