Bombay HC in case of Vodafone and PMP Auto had some years back ruled that TP provisions are not attracted on issue of shares to and from Foreign AE. However, thereafter definitation of income has undergone major change.
post the changes are TP provisions applicable in FY 2018-19 on allotment of equity shares by Foreign AE? is it necessary to obtain form 3CEB in this regard?
CAclubindia
