The transfer of shares of an Indian company by a holding Company to another holding Company results in disallowance of brought forward losses
Court :
ITAT
Brief :
The transfer of shares of an Indian company by a holding Co (Yum Asia) to another holding Co (Yum Singapore) results in change of “beneficial ownership” of shares and results in disallowance of b/fd losses even though the ultimate beneficial owner remains Yum USA. The corporate veil cannot be pierced to regard the ultimate holding Co as the beneficial owner
Citation :
Yum Restaurants (India) Pvt. Ltd vs. ITO (Delhi High Court)
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