AAR on tax liability of a partnership firm to be formed in Canada by a Canadian company for executing its PSCs in India

RELEVANT PARAGRAPH  10.1 It is the common stand of both – the applicant and the Revenue, that the nature of income arising from the transfer of the applicant’s participating interest in Amguri block to the proposed partnership firm, shall be capital gains. Where they differ is regarding the mode of computation of that income. Whereas the applicant submits that sub-section( 3) of section 45 of the Act provides a particular mode of computation of value of consideration, the contention of the Revenue is that the said transaction shall be in the nature of international transaction bet...