The question of extra territorial application of the tax statutes has never been free from varied interpretations. Similarly, the orbit of tax import vis-a-vis non-residents has always been riddled with debate.
Considering the spate of M&A activities happening in India, the extra territorial application of tax statutes has become an epicentre of discussion by courts.
The recent notable judgments of the courts, which have been carefully watched by the global business community, point to the wide ramification of the same. They have created anxiety among non-residents, be it corporate assessee or individual tax payers.
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Aseem Chawla is a partner at Amarchand & Mangaldas & Suresh A Shroff & Co, where Saurav Sood is an associate. The views expressed in this article are those of the authors and do not reflect the official policy or position of Amarchand Mangaldas.
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aseem.chawla@amarchand.com
