https://www.taxtmi.com/caselaws?id=293810 The Authority for Advance Rulings determined that Explanations 6 and 7 to Section 9(1)(i) of the Income-tax Act have retrospective effect. Income from the transfer of shares in AIS, where less than 50% of the value is derived from Indian assets, is not taxable in India. Section 115JB does not apply to the foreign companies involved, and there is no withholding tax liability under Section 195 for the buyer. en-us Wed, 18 Mar 2020 00:00:00 +0530 Thu, 04 Mar 2021 18:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=293810 The Authority for Advance Rulings determined that Explanations 6 and 7 to Section 9(1)(i) of the Income-tax Act have retrospective effect. Income from the transfer of shares in AIS, where less than 50% of the value is derived from Indian assets, is not taxable in India. Section 115JB does not apply to the foreign companies involved, and there is no withholding tax liability under Section 195 for the buyer. Case-Laws Income Tax Wed, 18 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=293810