Capital gain exempted under sec. 47 isn't liable to MAT as it doesn't fall in definition of income

IT : If a receipt/gain is not "income" within the meaning of section 2(24), it cannot be subjected to MAT u/s 115JB .Capital gains from transfer of asset by holding company to its Indian Wholly Owned Subsidiary which is tax exempt u/s 47(iv) is not chargeable to capital gains and consequently is not "income" within meaning of section 2(24)(vi) and hence cannot be included in computation of "book profit" for MAT purposes u/s 115JB