Whether the applicant is required to deduct tax under section 195 on payment made by it to foreign company for acquisition of shares and gains arising to it on transfer of shares is taxable in India. The application is admitted.
OC Oerlikon Corporation AG, In re (2021) 436 ITR 186 / 279 Taxman 1 / 199 DTR 39 / 319 CTR 386 (AAR)
S. 245R : Advance rulings-Deduction at source-Payment made to foreign company for acquisition of shares whether liable to deduct tax at source-Application admitted. [S. 9(1)(i), 195, 245R(2)]