https://www.taxtmi.com/caselaws?id=790725 Foreign company income generally cannot be assessed in resident shareholders' hands merely because they hold all or substantially all of the shares. The analysis notes that where the company is a separate juristic entity, owns the assets, earns the rental income and capital gains outside India, and there is no statutory charging provision or material to show that the structure is a sham or tax-avoidant device, the corporate veil cannot be pierced on a substance-over-form theory. In that situation, only dividend, if any, may be taxed in the shareholders' hands, and additions based on alleged beneficial ownership are unsustainable. en-us Fri, 24 Apr 2026 00:00:00 +0530 Wed, 29 Apr 2026 08:16:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790725 Foreign company income generally cannot be assessed in resident shareholders' hands merely because they hold all or substantially all of the shares. The analysis notes that where the company is a separate juristic entity, owns the assets, earns the rental income and capital gains outside India, and there is no statutory charging provision or material to show that the structure is a sham or tax-avoidant device, the corporate veil cannot be pierced on a substance-over-form theory. In that situation, only dividend, if any, may be taxed in the shareholders' hands, and additions based on alleged beneficial ownership are unsustainable. Case-Laws Income Tax Fri, 24 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790725