Bombay High Court Allows Petition Challenging TPO Order on Share Issuance to Non-Resident AE - Capital Receipt Not Taxable Under Transfer Pricing Provisions. The court held that issuance of equity shares at premium to non-resident Associated Enterprises is a capital account transaction not giving rise to income, and thus outside the scope of Chapter X of the Income Tax Act, 1961, following Vodafone India Services Pvt. Ltd. vs. Union of India.
18 Nov 2014The petitioner, M/s. Shell India Markets Pvt. Ltd., filed a writ petition under Article 226 of the Constitution of India challenging the order dated 3...






