Transfer of shares to a step-down subsidiary created in tax haven country to avoid tax couldn’t be held as gift

INCOME TAX : Where a step-down subsidiary was created by assessee in a tax haven country to act as a conduit to escape rigour of Indian Tax Laws and assessee transferred its shareholding in a company to said step-down company who in turn transferred stake in favour of a third party investor for a consideration, sole intention of assessee being corporate re-structuring, assessee was liable to tax under section 45; such transfer was not a gift to subsidiary company

from www.taxmann.com Latest Case Laws https://www.taxmann.com/topstories/101010000000197296/transfer-of-shares-to-a-step-down-subsidiary-created-in-tax-haven-country-to-avoid-tax-couldn’t-be-held-as-gift.aspx