TP: Purchase of Shares of AE can’t be regarded as International Transaction

M/s. TCG Life sciences Pvt. Ltd. Vs. DCIT (ITAT Kolkata) Assessee raised an objection that since the subscription/purchase of shares being on capital account and therefore does not give raise to any “income” and hence the provisions of Sec. 92 of the Act would not be applicable. The DRP did not agree with the submissions of the Assessee and it held that such transaction was also an international transaction and ALP of such transaction has to be computed in accordance with the provisions of Sec.92 of the Act. In AY 2011-12, the DRP upheld the quantum of addition and the rate of interest det...