HC decides TP issue of undervaluation of shares in favour of shell; follows ratio of Vodafone's case

IT/ILT : The Bombay High Court in the instant case held in favour of Shell India ('petitioner') on the issue of applicability of Transfer Pricing provisions in case of issue of shares. In this regard, the High relied upon decision in the case of Vodafone India Services (P.) Ltd. v. Union of India [2014] 50 taxmann.com 300 (Bombay). In case of Vodafone India (Supra) it was held that the jurisdiction to apply Chapter-X of the Act would occasion only when income arises out of International Transact