https://www.taxtmi.com/news?id=13890 Receipts on issuance of shares to a non-resident holding company are transactions on the capital account and do not give rise to taxable income; consequently Chapter X transfer pricing provisions and re-computation of Arm's Length Price cannot be invoked where no income arises. The Transfer Pricing Officer's ALP adjustment, its treatment as a deemed loan with associated interest, and related orders were quashed for lack of jurisdiction, and the government has accepted the High Court ruling and will not pursue further appeal, extending the position to similar cases. en-us Thu, 29 Jan 2015 10:15:56 +0530 Fri, 30 Jan 2015 15:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/news?id=13890 Receipts on issuance of shares to a non-resident holding company are transactions on the capital account and do not give rise to taxable income; consequently Chapter X transfer pricing provisions and re-computation of Arm's Length Price cannot be invoked where no income arises. The Transfer Pricing Officer's ALP adjustment, its treatment as a deemed loan with associated interest, and related orders were quashed for lack of jurisdiction, and the government has accepted the High Court ruling and will not pursue further appeal, extending the position to similar cases. News - Thu, 29 Jan 2015 10:15:56 +0530 https://www.taxtmi.com/news?id=13890