Overseas subsidiary with single shareholder is a separate legal entity for tax purposes

AIA Engineering Ltd Vs. Add CIT (ITAT Ahmedabad)– It was  held that investment made by AIA Engineering Limited (AIA India or the assessee) in Vega Industries (Middle East) FZE (Vega UAE) shall not be treated as investment in a proprietary concern of AIA India though Vega UAE had no other shareholder.Vega UAE is considered to be established as an independent corporate entity with separate financial liability from those of its owner in accordance with the memorandum of incorporation and the only situation where the owner will be treated as

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