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High Court of Bombay Examines Jurisdictional Challenge to Transfer Pricing Adjustment on Equity Share Issuance. Whether Alleged Shortfall in Premium Constitutes Income from International Transaction Under Chapter X of Income Tax Act, 1961.

Vodafone India Services Pvt. Ltd. (the Petitioner), a wholly owned subsidiary of a non-resident holding company, required funds for its telecommunicat...

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Bombay High Court Hears Writ Petition Challenging Taxation of Alleged Shortfall in Share Premium Under Transfer Pricing Provisions. The Dispute Centers on Whether Chapter X of the Income Tax Act, 1961 Can Apply When No Actual Income Arises from the International Transaction.

The petitioner, Vodafone India Services Pvt. Ltd., a wholly owned subsidiary of a non-resident holding company, issued 2,89,224 equity shares at a pre...