Trace Your Case

ISSUE:

Whether the Indian revenue authorities had the jurisdiction to tax an offshore transaction of transfer of shares between two non-resident companies whereby the controlling interest of an Indian resident company is acquired by virtue of this transaction?

RULE:

Indian revenue authorities do not have jurisdiction to impose tax on an offshore transaction between two non-residents companies where in controlling interest in a (Indian) resident company is acquired by the non-resident company in the transaction.

Subscribe to Read More.
Login Join Now