Capital gains on transfer by a foreign company of shares in another foreign company holding assets in India is taxable in India

To put the facts very simply in a narrow compass , the assessee company is a tax resident of United Kingdom which was incorporated on 26th of June 2006. On 30/06/2006, it entered into the share exchange agreement with Cairn energy Plc where the entire issued share capital of 9 wholly owned subsidiary of Cairn energy plc were exchanged by issue of 221444034 shares of appellant at the face value of GBP 1 each. Thereafter the appellant entered into a share exchange agreement dated 07/08/2016 with another company Cairn India Holdings Ltd which was incorporated on 02/08/2006 in Jersey and appellan...