Category: Copal Group

Delhi HC joins dots on indirect transfer debate

The verdict serves as reference for invoking treaty abuse provisions in the absence of General Anti-Avoidance Rules Mukesh Butani  September 7, 2014 Last Updated at 22:33 IST In a ruling demonstrating wise judicial discipline, the Delhi High Court (HC) recently upheld non-taxability of sale of shares in an offshore company… – Continue reading

First landmark ruling on Indian indirect transfer taxes! Delhi High Court restricts their applicability

The Delhi High Court upholds the non-taxability of gains from sale of shares of overseas entities by the Copal Group to the Moody’s Group. Interpretation of the indirect transfer tax provisions in a restrictive manner. 50% threshold for substantiality based on guidance by OECD/ UN material and Shome Committee Report… – Continue reading