No capital gain on indirect transfer of Indian shares if no consideration accrued to transferor

AUTHORITY FOR ADVANCE RULINGS (INCOME TAX), NEW DELHI Credit Suisse (International) Holding AG, In re Justice P.K. Balasubramanyan, Chairman A.A.R. No. 956 of 2010 August 22, 2012 RULING The applicant is a company incorporated under the laws of Switzerland and is a fully owned subsidiary of another company referred to as ‘company C’ hereinafter, incorporated in Switzerland. The applicant had set up a wholly owned subsidiary in India under the Indian Companies Act, 1956. For convenience, the Indian company is henceafter referred to as ‘I Co.’ The applica...