Piercing corporate veil to identify beneficial ownership u/s 79 not permitted: HC

Brief of the Case

Delhi High Court held In the case of YUM Restaurants (India) Pvt. Ltd. vs. ITO that both entities i.e Yum Asia and Yum Singapore which hold the shares of assessee, Yum India, for pre and post restructuring period respectively, were distinct entities. Although they might be AEs of Yum USA, the ultimate holding company, there is nothing to show that there was any agreement or arrangement that the beneficial owner of such shares would be the holding company, Yum USA. The question

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