https://www.taxtmi.com/caselaws?id=331902 The judgment concluded that there was no transfer on amalgamation as SSBS would stand dissolved, and even if considered a transfer, no consideration accrued to SSBS, thus no capital gains could be levied. The non-discrimination clause in Article 25 of the DTAA ensured that the exemption under section 47(vi) was available to SSBS. Additionally, no consideration accrued to BSS, shareholders of SSBS were not chargeable to tax in India, BSS was not liable to withhold tax under section 195 of the ITA, and transfer pricing provisions were deemed inapplicable due to the absence of tax chargeability. en-us Wed, 17 Aug 2016 00:00:00 +0530 Thu, 17 Nov 2016 18:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331902 The judgment concluded that there was no transfer on amalgamation as SSBS would stand dissolved, and even if considered a transfer, no consideration accrued to SSBS, thus no capital gains could be levied. The non-discrimination clause in Article 25 of the DTAA ensured that the exemption under section 47(vi) was available to SSBS. Additionally, no consideration accrued to BSS, shareholders of SSBS were not chargeable to tax in India, BSS was not liable to withhold tax under section 195 of the ITA, and transfer pricing provisions were deemed inapplicable due to the absence of tax chargeability. Case-Laws Income Tax Wed, 17 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331902