Taxability of indirect transfers: shares deriving value from India are taxable, with exemptions for limited non resident ownership and control. Shares or interests in an offshore entity will be treated as deriving substantial value from India where India-located assets exceed a threshold and constitute at least half of total assets; asset value is fair market value on the specified date. A specified date links to the accounting period end or the transfer date if book value rises materially. Transfers by non-residents are excluded where, in the prior twelve months, the transferor (alone or with associated enterprises) lacked management or control and did not hold more than five percent voting power or interest; if assets are not all in India, taxable income is apportioned to India-located assets. Associated enterprise uses transfer-pricing definition.