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| Topic: |
Business
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| Number of pages / Number of words: |
5 / 1350 |
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Now, the above discussion shows that the “computation†provisions for determination of the ALP are likely to fail in the subject case (as none of the prescribed methods are applicable for undertaking valuation of shares) and hence, the charging section – that is, 92C would fail – resulting in an argument that the transfer pricing regulations would not apply in the instant case...
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A Inc holds shares of C Ltd, which is an Indian company. Transfer of shares of C Ltd. by A Inc to B Inc would have a bearing on the assets of A Inc as well as B Inc and thus this transaction would classify as an international transaction.
Having established that the subject transaction is an international transaction, the capital gains arising from an international transaction will constitute ‘income’...
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