No MAT on foreign Co. as it doesn't have PE in India; AAR follows Government's stand

IT/ILT: Where a Mauritian Company a 100 per cent subsidiary of parent company proposed to transfer shares held by it in Indian company in favour of a company proposed to be incorporated in Singapore with an object of group re-organization, the transaction having begun almost 20 years back, it could not be said that it was for tax avoidance and, therefore profit arising from such transaction won't be subjected to tax in India in terms of Article 13 of of DTAA between India and Mauritius. Further,