Ultimate Holding Company should not be considered as beneficial owner of gains arising to Subsidiary Company on sale of investments held by such Subsidiary Company

Facts

• The applicant, a Dutch company was incorporated on 11 August 2008. On 6 November 2008, it acquired all the shares of an existing Indian company from another group company located in Germany. The shares were acquired for a consideration of INR 100 million.
• Post acquisition, the applicant made a further investment of INR 1100 million in the Indian subsidiary company. Both the companies (Dutch Company and German Company) are ultimately held by another German company with extensive manufacturi

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