https://www.taxtmi.com/caselaws?id=60380 Transfer of shares in Indian companies was treated as a taxable transfer of a capital asset under domestic law, and treaty protection under the Indo-UK and Indo-Netherlands DTAAs was denied because the residence and exemption requirements were not met. The restructuring arrangement, with shares in the transferee company received as consideration, did not fall outside section 45(1), and no exemption was established under sections 45(3) or 47(iii). Estoppel could not restrict tax liability to the amount mentioned in the no-objection certificate, and the administrative certificate did not override statutory computation. The cross-objections on limitation, section 143(1)(a), and accounting period also failed. en-us Fri, 30 Mar 2001 00:00:00 +0530 Wed, 05 Jan 2011 10:48:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=60380 Transfer of shares in Indian companies was treated as a taxable transfer of a capital asset under domestic law, and treaty protection under the Indo-UK and Indo-Netherlands DTAAs was denied because the residence and exemption requirements were not met. The restructuring arrangement, with shares in the transferee company received as consideration, did not fall outside section 45(1), and no exemption was established under sections 45(3) or 47(iii). Estoppel could not restrict tax liability to the amount mentioned in the no-objection certificate, and the administrative certificate did not override statutory computation. The cross-objections on limitation, section 143(1)(a), and accounting period also failed. Case-Laws Income Tax Fri, 30 Mar 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=60380