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Legitimate Share Issuance to Foreign Investors with Fair Valuation is Not Tax Avoidance, Clarifies Income Tax Law.
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....Tax avoidance, Tax evasion or Tax planning - when there are material evidences to substantiate that the shares were issued to foreign investors, and the conversion of the share was in accordance with the terms of issue of the preference shares appropriately justified with the fair valuation, there is no case treating such an issue/conversion as a means of tax avoidance.....