https://www.taxtmi.com/caselaws?id=77365 Cross-border merger and divestment transactions were analysed for Indian taxability, concluding that a mere transfer of a foreign share did not encompass the full transaction; attendant rights and entitlements transferred constitute capital assets and are taxable as income sourced to India. The relevant legal basis is the source of income doctrine: where profits arise from divestment of interests in India, income accrues in India and attracts taxability, including obligations to deduct tax at source. The nexus between the transaction and Indian fiscal jurisdiction determines jurisdiction of Indian tax authorities to issue notices and tax the gains. en-us Wed, 08 Sep 2010 00:00:00 +0530 Fri, 30 Jan 2026 15:58:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=77365 Cross-border merger and divestment transactions were analysed for Indian taxability, concluding that a mere transfer of a foreign share did not encompass the full transaction; attendant rights and entitlements transferred constitute capital assets and are taxable as income sourced to India. The relevant legal basis is the source of income doctrine: where profits arise from divestment of interests in India, income accrues in India and attracts taxability, including obligations to deduct tax at source. The nexus between the transaction and Indian fiscal jurisdiction determines jurisdiction of Indian tax authorities to issue notices and tax the gains. Case-Laws Income Tax Wed, 08 Sep 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=77365