2008 (12) TMI 3 - HC - Income Tax

The very purpose of entering into agreements between the two foreigners is to acquire the controlling interest which one foreign company held in the Indian company, by other foreign company. This being the dominant purpose of the transaction, the transaction would certainly be subject to municipal laws of India, including the Indian Income Tax Act - petitioner has withhold the information / documents deliberately - Petitioner accordingly was under obligation to withhold tax as required u/s 195.