VRT Limited is a company incorporated under the Companies Act, 1956 which is having two undertakings engaged in manufacture of cement and steel, decided to hive off cement division to RTY Limited a company incorporated u

VRT Limited is a company incorporated under the Companies Act, 1956 which is having two undertakings engaged in manufacture of cement and steel, decided to hive off cement division to RTY Limited a company incorporated under the Companies Act, 2013 by way of demerger. The net worth of VRT Limited immediately before demerger was ₹45 crore. The net book value of assets transferred to RTY Limited was ₹15 crore. The demerger was made in January, 2024. In the scheme of demerger, it was fixed that for each equity share of ₹10 each (fully paid up) of VRT Limited, two equity shares of ₹10 each (fully paid up) were to be issued. Mr. Manish held 30,000 equity shares in VRT Limited which were acquired in the financial year 2007-2008 for ₹4,00,000. He received 60,000 equity shares from RTY Limited consequent to demerger in January 2024. He sold all the shares of RTY Limited @ ₹10 in March, 2024. Based on the facts of the above information, answer each of following cases separately: Does the transaction of demerger attract any income tax liability in the hands of VRT Limited or RTY Limited ?