TMI Blog2014 (12) TMI 58X X X X Extracts X X X X X X X X Extracts X X X X ..... Tax [2014 (10) TMI 278 - BOMBAY HIGH COURT] - there is a short fall in the amounts received on issue of equity shares and conversion of Preference shares into equity shares when benchmarked against the Arm’s Length Price (ALP) to be received on issue and conversion - This short fall is characterized as income arising from International Transactions and is being subjected to tax for Assessment Yea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e non resident Associated Enterprises into equity shares would attract the provisions of Chapter X of the Income Tax Act, 1961. ( the Act ). 2. It is agreed between the Counsel that the above issue stands covered in favour of the petitioner by virtue of the decision of this Court in Vodafone India Services Pvt. ltd. vs. Union of India 368 ITR Page 1 (Vodafone IV). 3. This petition challenges ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bjection is scheduled before the DRP on 24 November 2014. The petitioner is not withdrawing its application before the DRP as there are other issues being urged before it. 5. In the above view, we see no reason to entertain this petition. However, it goes without saying that the DRP will decide the petitioner's objection in the light of agreed position between the parties in the present fac ..... X X X X Extracts X X X X X X X X Extracts X X X X
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