Transfer pricing adjustment – Whether issue of shares at a premium by the Petitioner to its non-resident holding company gave rise to any income from an admitted International Transaction – Held that – The amounts received on issue of share capital including the premium is undoubtedly on capital account and does not give rise to income and, hence, not liable to transfer pricing adjustment.
Vodafone India Services Pvt. Ltd. Versus Union of India, Addl. Commissioner of Income Tax, Dy. Commissioner of Income Tax – 2014 (10) TMI 278 – BOMBAY HIGH COURT – Income Tax