Among others, the two
propositions that do not seem to have been explored (or fully exploited ad
addressed) ARE:
1. 1. Transfer of ‘controlling interest’ by a NR to
another NR , through transfer of shareholding
in an Indian company , is, by any
logic or reasoning, not exigible to taxation
in India.
I 2. In any view, the concept of ‘indirect
transfer’, lately introduced, through the amendments of sec 9- do not help the Revenue to so tax; for, even
on the premise that the deeming provisions enable the Revenue to do so, a computation of the
chargeable gains will result in a ‘nil’ figure.
RESOURCES (Study Material) -
TAGS > ‘Vodafone’; ‘Indirect Transfer’; ‘Intellectual Property’ ; 'Intangible Asset’; ‘Share v (X) 'Controlling Interest ‘; ‘ Treaty Override’ ...
TAGS > ‘Vodafone’; ‘Indirect Transfer’; ‘Intellectual Property’ ; 'Intangible Asset’; ‘Share v (X) 'Controlling Interest ‘; ‘ Treaty Override’ ...
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