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Please enter your Email ID. However there is no clarity on how these proposed provisions would apply in the event the consideration is not determinable, although the principle laid down B. The mere fact that money consideration has not passed would not put the transfer out of the domain of Section In this case, the AAR has not really dealt with the fact whether the proposed transaction would be exempt from capital gains by virtue of the exemption provided in Section 47 iii. Save time and let us provide you with verified contacts. Please enter your name.

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Contact Seller Request a quote. The contents of this hotline should not be construed as legal opinion.

Therefore, the liability to pay capital gains tax does not arise. The mere fact that money consideration has not passed would not put the transfer out of the domain of Section Tell us what you need by filling in the form.

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Opportunities and Misconceptions December 06, Webinar: Please enter Mobile Number. The Applicant proposes to restructure the group with a view to split its business into two — one owning business in Europe and the other owning business in Asia, North Africa and Latin America.

Capital gains cannot arise on the basis of uncertain and indefinite future contingencies or hypothetical and imaginary estimations. Please enter your name.

Srinivasa Shetty 2 when there is a case to which the computation provision cannot be applied at all, it is not intended to fall within the charging section. Giving GCs Sleepless Nights?


We have discussed the Budget implications on such transactions below in our analysis. However, in light of the recent Budget proposals announced by the Finance Minister on February 26,it is unclear whether such transactions will be taxable in India. While we can rely on B.

Master Data Management (MDM) in Bhubaneshwar by Amitech Solutions | ID:

We are here to help! Call Send a quick message. Tell us what you need by filling in the form. With respect to the applicability of transfer pricing provisions to the proposed transaction, the AAR relied on the ruling given in Dana Corporation 3 wherein the application of transfer pricing provisions was ruled out in a case where the income is not chargeable to tax in the first place. We can help you take guesswork out of the CDI and MDM implementation to reduce risk and ensure maximum business efficiency and insight by defining single reference for master data across disparate sources.

Arguments The Applicant contended that pursuant to the proposed transaction, no profit or gain will accrue or arise to the Applicant as no consideration can be evaluated in terms of money as a result of the proposed transfer of shares.

Master Data Management (MDM)

We help amiyech clients to manage and extract actionable insights from their data assets. However, as per the Budget proposals transactions such as gift of shares or transfer of shares for a consideration less than the fair market value of shares undertaken by a company may now be taxable with effect from June under the proposed amendment to Section 56 of the ITA as Income from Other Sources.

These types of intra-group transactions are not uncommon and this ruling is quite helpful to determine the taxability of such transactions in India.


In cases where there is a capital gain accruing or arising, a transfer of a capital asset by way of gift is still exempt from capital gains tax in view of Section 47 iii.

Tax Hotline March 03, Business Intelligence Analytics Services. In fact, interestingly, the AAR first sought to examine whether there is a capital gain accruing or arising to the Applicant. Receive Verified supplier details. We are here to help! Ruling The AAR analysed the provisions relating to capital gains under the ITA and stated that the charging section relating to capital gains and the computation provisions together constitute an integrated code.

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