3 results for “penalty u/s 271”+ Section 147clear
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u/s 46A in the hands of shareholders. However, taking the benefit of Article 13 of India-Mauritius DTAA, which provides for capital gain arising on transfer of shares of Mauritius resident taxable in that country and under Mauritius tax laws capital gain is totally exempt, entire transaction used to escape the tax net. Thus to plug this loop hole