vodafone transfer pricing

Vodafone Transfer Pricing Ruling by Mumbai HC Final : CBDT

Its official now , that CBDT has issued Instruction No.2/20l5 to its officer that the the Mumbai High Court ruling in transfer pricing ruling case of Vodafone case related to transfer pricing adjustment on account of share premium is final and should be followed by all officials.This case is also very important from point of view that if any company issues shares at less than market price to a non resident , the notional gain to the non resident can not be taxed in resident’s hand , because as per the Mumbai High Court , charging section fails to tax such imaginary gains.