DSIJ Mindshare

The Tax Department may raise an issue in the assessment but the Court decisions will help you.

The provisions of Section 194 IA are applicable only if there is a transferor and a transferee.

If you are a non-resident under the Income Tax Act, then any income accrued or earned outside India is not taxable in India.

The transaction between two nonresident foreign citizens is with respect to assets which is situated in India.

The moment you convert business assets into capital assets i.e. investment, business income arises.