AAR held that considering the facts of the case Share transaction between two non-resident entities are not liable to tax in India therefore buyer is not required to deduct tax at source.
Symphony Technology Group Llc, In Re (2021) 432 ITR 165 (AAR)
S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Non-resident-Capital gains-Share transaction between two non-resident entities are not liable to tax in India-Buyer is not required to deduct tax at source. [S. 195, ITAT R. 11UB IIUC]