"Round- Tripping" or "Treaty Shopping"

Demand on capital gains on Idea share sale by Mauritius subsidiary; Fema and telecom regulation violations also alleged. The income tax (I-T) department has sent a notice to Tata Industries, raising a demand of Rs 298 crore on capital gains on the sale of shares in Idea Cellular, held through a wholly-owned Mauritius-based subsidiary, Apex Investments, to Birla TMT Holdings in India. Although the amount is not large, the notice, which was sent last month, is significant because, I-T department sources said, it was the first discovered case of "round- tripping" or "treaty shopping" and has significance for Indian companies structuring offshore deals. The notice was sent under section 143(3) of Income tax Act , 1961, but the demand for capital gains has been made under section 93 (3) of the Income Tax Act.
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