https://www.taxtmi.com/caselaws?id=6588 A mere change in the holder's status, from trustee to depository, did not amount to a transfer of a capital asset situated in India because there was no sale, exchange, extinguishment of rights, or alteration in ownership of the Indian securities. The AAR treated the decisive factor as continuity of the same holdings under a different nomenclature, supported by SEBI's communication, and held that the UK reorganisation did not trigger chargeability under section 2(47) read with section 9(1)(i) of the Income-tax Act, 1961. The non-resident applicant was therefore not chargeable to tax in India on that transaction. en-us Fri, 29 Jul 2005 00:00:00 +0530 Thu, 15 Jan 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6588 A mere change in the holder's status, from trustee to depository, did not amount to a transfer of a capital asset situated in India because there was no sale, exchange, extinguishment of rights, or alteration in ownership of the Indian securities. The AAR treated the decisive factor as continuity of the same holdings under a different nomenclature, supported by SEBI's communication, and held that the UK reorganisation did not trigger chargeability under section 2(47) read with section 9(1)(i) of the Income-tax Act, 1961. The non-resident applicant was therefore not chargeable to tax in India on that transaction. Case-Laws Income Tax Fri, 29 Jul 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6588