https://www.taxtmi.com/caselaws?id=791635 Payments for acquisition of shares of a Mauritius company from US resident shareholders were discussed in the context of section 195, which applies only where the sum paid is chargeable to tax in India. The note explains that, on the transaction date, the prevailing law after Vodafone did not tax indirect transfer of foreign shares merely because their underlying value was linked to Indian assets. It further states that the retrospective insertion of Explanations 4 and 5 to section 9(1)(i) expanded the chargeability fiction, but did not create a withholding obligation for a past transaction when that fiction was not then on the statute book. On that basis, no section 195(2) application or default under sections 201(1) and 201(1A) arose. en-us Wed, 15 Apr 2026 00:00:00 +0530 Thu, 14 May 2026 09:01:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791635 Payments for acquisition of shares of a Mauritius company from US resident shareholders were discussed in the context of section 195, which applies only where the sum paid is chargeable to tax in India. The note explains that, on the transaction date, the prevailing law after Vodafone did not tax indirect transfer of foreign shares merely because their underlying value was linked to Indian assets. It further states that the retrospective insertion of Explanations 4 and 5 to section 9(1)(i) expanded the chargeability fiction, but did not create a withholding obligation for a past transaction when that fiction was not then on the statute book. On that basis, no section 195(2) application or default under sections 201(1) and 201(1A) arose. Case-Laws Income Tax Wed, 15 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791635