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2005 (7) TMI 32 - AAR - Income TaxTax resident of U.K. - registered with SEBI as a Foreign Institutional Investor (FII) & made investments in Indian securities – held that when no tax liability arises under the Act, the treaty per se does not create any tax liability – there has been no transfer of shares in Indian companies held by the applicant as a consequence of the reorganisation of the applicant in U.K. - in respect of the transaction, the applicant is not chargeable to tax in India or under DTAA
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