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It is found that the courts of different countries have taken different stand on the issue. While, England and USA seem to be strict, Australian courts are liberal and hesitant to extend the liability of subsidiary to holding company. In addition to this certain supranational organizations like European Union, have also codified norms to deal with such situations...

These aspects have been attempted to explain better by use of case laws.

2. Statutory definitions of holding and subsidiary company under different jurisdictions:

In India, Companies Act, 1956 largely governs the affairs all companies except few exceptions like banking companies which are also governed by Banking Regulation Act...

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