AAR cannot be approached for a ruling only on a part of a transaction

AUTHORITY FOR ADVANCE RULINGS (INCOME-TAX) ZD, In re P.K. Balasubramanyan, Chairman, J. A.A.R. No. 1098 of 2011 June 8, 2012  RULING 1. The applicant is a company registered under the laws of Panama. India has not entered into a Double Taxation Avoidance Convention with Panama. 2. The applicant holds shares in two Indian companies, both governed by the Companies Act, 1956. Both are public limited companies. The shares of one were acquired by the applicant in a public issue in the year 1991, augmented by an acquisition under a rights issue in the year 1995. The shares in the o...