by Majmudar & Partners | Feb 1, 2022 | Authored by Ravi S. Raghavan, Policy & Governance Updates, Tax
Introduction India’s Union Budget (the “Budget”) was announced on February 1, 2022, and the Finance Bill, 2022 (the “Finance Bill”) was tabled in Parliament. The Finance Bill will be discussed in Parliament before its enactment, and therefore, it is likely that...
by Ravi S. Raghavan | Aug 13, 2021 | Authored by Ravi S. Raghavan, Tax
Background The taxability of capital gains arising from the transfer of shares of a foreign company that derives substantial value from Indian assets (commonly referred to as an indirect share transfer) has been a litigative issue in India. In January 2012, in...
by Ravi S. Raghavan | Jun 10, 2021 | Authored by Ravi S. Raghavan, Tax
Facts Morgan Stanley Mauritius Company Limited (“MSMCL”) is a company incorporated in Mauritius and holds a valid tax residency certificate issued by the Mauritius tax authorities. In the financial year 2014-15, MSMCL invested in Indian Depository Receipts (“IDRs”)...
by Ravi S. Raghavan | Mar 24, 2021 | Authored by Ravi S. Raghavan, Tax
In two interesting cases, one from the Delhi High Court and the other from the Chennai Income Tax Appellate Tribunal (the “Chennai ITAT”), the importance of a share valuation report in settling tax disputes has, once again, come to the fore. The Delhi High Court case...
by Ravi S. Raghavan | Feb 12, 2021 | Authored by Ravi S. Raghavan, Tax
Recently, in the case of Technip France SA, the Authority for Advance Rulings (the “AAR”) dealt with the issue of taxability in India of an offshore supply of equipment and provision of offshore services. The AAR held that the payment for the offshore supply was not...
