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    <title>2014 (12) TMI 58 - BOMBAY HIGH COURT</title>
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    <description>Issue of equity shares to a non-resident Associated Enterprise, and conversion of preference shares into equity shares, was treated as not giving rise to income attracting Chapter X transfer pricing adjustments under the Income-tax Act, following the Bombay High Court&#039;s earlier ruling in Vodafone India Services Pvt. Ltd. v. Union of India. On that basis, the settled position was that no income arose from the impugned share transactions in the stated facts. The writ petition was nevertheless not entertained because objections to the draft assessment order were already pending before the Dispute Resolution Panel, and the tax authority was directed to proceed consistently with that position.</description>
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      <description>Issue of equity shares to a non-resident Associated Enterprise, and conversion of preference shares into equity shares, was treated as not giving rise to income attracting Chapter X transfer pricing adjustments under the Income-tax Act, following the Bombay High Court&#039;s earlier ruling in Vodafone India Services Pvt. Ltd. v. Union of India. On that basis, the settled position was that no income arose from the impugned share transactions in the stated facts. The writ petition was nevertheless not entertained because objections to the draft assessment order were already pending before the Dispute Resolution Panel, and the tax authority was directed to proceed consistently with that position.</description>
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