TRANSWORLD GARNET COMPANY LIMITED Vs. COMMISSIONER CONCERNED DIRECTOR OF INCOME TAX

JUDGEMENT

(1.) THE applicant, Transworld Garnet Company Ltd, is a company registered under the laws of Canada. It is engaged in the business of mining, processing and supply of industrial garnet. It is holding 74 per cent of the equity share capital in Transworld Garnet India Private Limited (TGI). The applicant acquired the shares in TGI in lots as below:

(2.) THE applicant draws attention to Section 48 of the Income Tax Act 1961(Act) which reads as under:

(3.) WITH this background, the applicant seeks the ruling of this Authority on the following questions: