Judicial update: [FIRST DECISION ON RETROSPECTIVE AMENDMENT TO SECTION 9] There can be no recourse to Explanation 5 to enlarge scope of section 9(1) so as to bring to tax gains or income that may arise from transfer of an asset situated outside India, which does not derive bulk of its value from asset situated in India Gains arising from sale of a shares of a company incorporated overseas, which derives less than 50 per cent of its value from assets situated in India would not be taxable under section 9(1)(i) read with Explanation 5 thereto DIT(Intl Tax)-vs-Copal Research Ltd., Mauritius (Delhi high court)
Posted on: Mon, 15 Sep 2014 02:28:38 +0000
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