training presentation - lo,bo,po,fdi

India Entry - Liaison Office (LO), Branch Office (BO),

Project Office (PO), Foreign Direct Investment (FDI)

India Entry Options

A representative office set up

primarily to explore and

understand business investment

climate.

No commercial activities carried

out.

Channel of communication

An establishment carrying on

substantially the same activity as

its HO.

Suitable for setting up temporary

offices.

An establishment set up for the

limited purpose of executing a

specific project.

Also called site office.

Liaison Office Branch Office Project Office

FDI

FIIs – Foreign Institutional Investors, NRIs – Non Resident Indians, PIO – Persons of Indian Origin, QFI – Qualified Institutional Investors

Foreign Venture

Capital

Investments

Automatic

Route

Foreign

Investments

Other

Investments ( G -

Sec , NCDs , etc )

Foreign Direct

Investments

Foreign Portfolio

Investments

Investments on

non - repatriable

basis

Government

Route

Persons Resident

outside India

SEBI regd .

FVCIs

NRIs , PIO ,

QFIsFIIs

VCF IVCUs

NRIs , PIONRIs , PIO ,

QFIs

LO BO PO - Suitability

Branch Office

• Export / import of goods

• Rendering professional or consultancy

services

• Promoting technical or financial

collaborations

• Representing parent company in India

and acting as buying/selling agent in

India

• Carrying out research work in which

parent company is engaged

• Rendering services in IT and development

of software in India; providing technical

support

• Representing a foreign airline / shipping

company

Liaison Office

• Representing the parent Company in

India

• Promoting export/import from/to India

• Promoting technical/financial

collaborations between the parent

companies and companies in India

• Acting as a communication channel

between the parent company and Indian

companies

Project Office

• There are no specific permitted activities

for a Project office

• They have secured a contract from an

Indian company to execute a project in

India; and

• The project is funded directly by inward

remittance from abroad; or

• The project is funded by a bilateral or

multilateral International Financing

Agency; or

• A company or entity in India awarding the

contract has been granted Term Loan by a

Public Financial Institution or a bank in

India for the project.

FDI suitability

FDI is prohibited in the following sectors

• Lottery Business including Government/private lottery, online lotteries, etc.

• Gambling and Betting including casinos etc.

• Chit funds

• Nidhi company

• Trading in Transferable Development Rights

• Real Estate Business or Construction of Farm Houses

• Manufacturing of cigars, cheroots, cigarillos and cigarettes, of tobacco or of tobacco substitutes

• Activities not open to private sector investment (such as atomic energy and railway transport)

Setting up BO/LO/PO

• Prior approval of RBI required in the following cases for setting up BO/LO/PO in India:

- Country Specific Restrictions– Applicant is a citizen of or is registered/citizen in Pakistan

- Region/State Specific Restrictions - The applicant is a citizen of or is registered/incorporated in Bangladesh, Sri Lanka,

Afghanistan, Iran, China, Hong Kong or Macau and the application is for opening a BO/LO/PO in Jammu and Kashmir, North East

region and Andaman and Nicobar Islands;

- Sector Specific Restrictions - The principal business of the applicant falls in the four sectors namely: Defense, Telecom, Private

Security and Information and Broadcasting.

- Type of Organization - The applicant is a Non-Government Organization (NGO), Non-Profit Organization, Body/ Agency/

Department of a foreign government.

Liaison Office(LO), Branch Office (BO), Project Office

(PO)

General Criteria for LO/BO/PO

• Type of entities that can open LO/BO/PO

- Company / Body corporate

- Firm/LLP

- Other association of individuals

incorporated outside India, in sectors where 100% FDI is allowed

• Track record for entities applying for BO/LO

LO BO

Track record

of profits

Preceding 3 financial

years

Preceding 5 financial

years

Net worth Atleast USD 50,000 Atleast USD 100,000

Applicants who do not satisfy the eligibility criteria and

are subsidiaries of other companies can submit a Letter

of Comfort from their parent company, subject to the

condition that the parent company satisfies the eligibility

criteria as prescribed here.

Procedure for application

Application in Form FNC

•Submission of application in Form FNC to designated AD Category I Bank along with required details

Grant of approval

•RBI shall allot a Unique Identification Number (UIN) to each BO/LO

•Post allotment of UIN, AD Category I Bank shall issue approval letter for establishing BO/LO in India

Set up of LO/BO/PO

•After receiving permission for setting up of BO/LO/PO, AD Category I Bank to be informed date on which BO/LO/PO is set up

•The approval granted shall lapse if the BO/LO/PO is not opened within six months from the date of approval letter

•The AD bank may grant an extension of six months in case the delay is due to reasons beyond control of the non-resident entity

•Prior approval of the RBI shall be required for any further extension

Opening of Bank Accounts

Liaison Office

•Only One Bank Account can be maintained at a given point of time without prior permission of RBI by an LO.

•Following transactions are permitted in such Accounts

•Credits : Funds received from office, refund of security deposits, taxes, duties etc. and Sale proceeds of assets of LO

•Debits : Local Expenses of the office

Branch Office

•Following transactions are permitted in such Accounts

•Credits : Funds received from HO for meeting expenses of the office and any other legitimate receivables in process of business operations

•Debits : expenses incurred by the BO & towards remittance of profit / winding up proceeds.

Project Office

•Can open two foreign currency accounts – One denominated in USD and other in home currency

•Conditions for opening Non- interest bearing foreign currency accounts• Contract governing project specifically

provides for payment in Foreign currency.

• Following transactions are permitted in such Accounts

• Debits : payment of project related expenditure

• Credits : foreign currency receipts from parent/ group company

• Accounts have to be closed on the completion of the project

Compliances - LO/BO/PO

LO BO PO

Annual Activity Certificate

(AAC)

To be submitted to –

• AD category – I bank

• DGIT Income Tax

To be submitted to –

• AD category – I bank

Validity Period 3 Years* 3 Years Tenure of the project

Extension Available subject to conditions Available subject to conditions N.A.

Additional Office If number of offices exceeds 4 (1 in each zone), the applicant

has to justify the need for additional offices & require prior

approval of the RBI

N.A.

*Except for NBFC & entities in Construction & development validity ~2 years (Cannot be renewed)

Funding, repatriation and Exit (1/2)

The AD bank may extend fund/non-fund based facilities to BOs and POs only

Remittance of profits/surplus:

• BOs permitted to remit profit net of applicable taxes

• POs permitted to make intermittent remittances before winding up / completion of project subject to sufficient provisioning for taxes

Closure of BO/LO/PO

• Application for closure to submitted with the following documents:

• Approval letter for establishing the BO/LO/PO

• Auditors certificate

• Confirmation from the applicant/parent company that no legal proceedings are pending

• Report from the Registrar of Companies regarding compliance with the provisions of the Companies Act, 2013

• AD bank to ensure that the BO / LO/ PO had filed their respective AACs

Funding, repatriation and Exit (2/2)

Transfer of assets

• Proposals considered only from BOs/LOs/POs who are adhering to the operational guidelines

• Transfer of assets by way of sale to the JV/WoS allowed only when the non-resident entity intends to close their BO/LO/PO

operations in India

• certificate is to be submitted from the Statutory Auditor furnishing details of assets to be transferred

• assets should have been acquired by the BO/LO/PO from inward remittances and no intangible assets such as good will, pre-

operative expenses should be included

• AD bank must ensure payment of all applicable taxes while permitting transfer of assets

• Credits to the bank accounts of BO/LO/PO on account of such transfer of assets will be treated as permissible credits

• Bonafide donation by BO/LO/PO of old furniture, vehicles, computers, etc. to NGOs or other not-for-profit organizations be

permitted

Other GuidelinesRequirement of obtaining PAN

• BOs / LOs / POs shall obtain Permanent Account Number (PAN) from the Income Tax Authorities on setting up of their office in India

• The existing PAN and bank accounts can be continued when an LO is permitted to upgrade into a BO

Transactions of LO/BO/PO

• BO/ LO/PO are required to transact through one designated AD bank only who shall be responsible for the due diligence and KYC norms

• BO/LO/PO can change their existing AD bank subject to both the AD banks giving consent in writing

Allowance of Term Deposit by AD category Bank

• Term deposit account for a period < 6 months in favour of a BO/LO/PO of a person resident outside India permitted subject to certain

conditions

ROC Compliances (if any)

General permission to carry out permitted/ incidental activities from leased property subject to lease period not exceeding five years

Taxation

Taxation

Branch Office & Project Office

• A BO/PO would constitute a PE in India

• In determination of the tax liability, expenses relating to PE in India would be deductible in computing taxable income

• While computing the profits attributable to PE in India, the deduction for head office expenditure will be restricted to 5% of taxable

income of branch.

• MAT will be applicable

Transfer Pricing Applicability

Branch Office

• Transactions between BO and HO subject to transfer pricing regulations.

Project Office

• In case of PO, Transactions are subject to transfer pricing regulations. - It is treated as an extension of the foreign company and is

liable to pay income tax.

Taxation Liaison Office

Since no commercial activities are undertaken, no income is

earned and hence no taxability

• Tax treaties also provide that maintenance of a fixed

place of business for the collection of information or any

other activity of a preparatory or auxiliary nature will not

lead to the creation of a PE or a taxable presence for the

foreign entity in India

• But PAN and TAN have to be obtained

• LO has to file an Annual Statement (Form 49C) under Sec

285 of IT Act within 60 days from end of FY

• The Annual Statement contains details of work carried

out by LO, information on employees, agents, distributor

and representatives etc. It helps the tax authorities to

determine whether the foreign entity has a PE in India.

Nike Inc - Karnataka HC

• Activities confined to purchase of goods for purpose of

export not taxable

• Identifying manufacturers, providing technical know-how

to manufacturers, acting as an interface between

manufacturers and parent entity cannot be construed as a

taxable activity

Brown & Sharpe Inc – Delhi ITAT

• Rendering services for promotion and sale of products is a

taxable activity

• In this case, the LO was registered with the ROC for

establishment of a place of business in India and filed IT

returns showing losses under Business Income. Further,

the variable component of employee salaries depended

on the number of sales orders placed.

• The LO received from the HO amounts over and above the

actual expenses incurred by it. Such excess amount was

held to be chargeable as business income.

To determine the taxability of LO in India, it is relevant to examine whether LO is

carrying out am important part of the business activity of the foreign company or it

is merely carrying out subsidiary and ancillary activities

Comparative Analysis

Comparative Analysis (1/2)Particulars Liaison Office (LO) Project Office (PO) Branch Office (BO)

Permissible activities Acting as a communication channel

between parent company and Indian

audience. However, it is not allowed to

undertake any business activity in India

Established provided the foreign parent

have secured a contract from an Indian

company to execute a project in India

Can carry out certain trading / service

activity / acting as a buying and selling

agent in India

Legal status Represents Parent Extension of Parent Extension of Parent

Ownership of immovable property Not allowed (but can be leased for limited

period)

Allowed to acquire Allowed to acquire

Life Initial approvals are given for 3 years Up to the life of the project Initial approvals are given for 3 years

Maximum Income Tax Rates / Minimum

Alternate Tax (‘MAT’)

No tax since no commercial activity being

carried out

40 % (In case of tax losses MAT @ 18.5 %

on book profits could be applicable) [to

be increased by applicable surcharge &

cess]

40 % (In case of tax losses MAT @ 18.5 %

on book profits could be applicable) [to

be increased by applicable surcharge &

cess]

Dividend Distribution Tax Not applicable Not applicable Not applicable

Control Generally with parent

Approvals Approvals of Authorised Dealer / Reserve

Bank of India

Approvals of Authorised Dealer / Reserve

Bank of India

Approvals of Reserve Bank of India

Comparative Analysis (2/2)Particulars Liaison Office (LO) Project Office (PO) Branch Office (BO)

Funding of Indian operations Through inward remittances received from the

Head Office outside India through normal

banking Channels

Through inward remittances or through

earnings from business operations

Through inward remittances or through

earnings from business operations

Repatriation of Funds As such, there may not be any repatriations

from the LO. However, in case of closure of

the LO, the balance cash may be repatriated

with the Reserve Bank of India approval

Approval not required for remittance of post-

tax profits to the foreign parent outside

India, subject to filing of requisite documents

with the AD

Approval not required for remittance of post-

tax profits to the Head Office outside India,

subject to filing of requisite documents with

the AD

Exit mechanism Prior approval of the RBI, ROC, IT authorities, certificate from the Auditors indicating and confirming certain facts and a confirmation from the

parent Company that there are no legal proceedings in any court in India pending and there is no legal impediment to the remittance would be

required

Foreign Direct Investment

Eligible Investors / Investees

Eligible Investors Investees

• Person Resident outside India / entity incorporated outside

India

• Entity / citizen of Bangladesh / Pakistan through

government route

• Investment from Pakistan not allowed in defense, space

and atomic energy

• NRIs resident in / citizens of Nepal / Bhutan (subject to

certain conditions)

• FII / NRI / FVCI / QFI as per regulations governing those

investors

• Special dispensation available to NRIs also available to

Company / trust / partnership firm incorporated outside

India and owned & controlled by NRIs

• Eligible NRIs can invest in NPS on repatriable basis

• Indian companies

• Firms and proprietorships

• Automatic: investment by NRI / PIO non-repatriation basis

• Approval route for all other cases

• Trusts – VCFs and Investment Vehicles

• LLP – in sectors where 100% FDI is permitted, subject to

certain conditions

• Investment Vehicles – including REITs, InvITs & AIFs

Eligible InvesteesFDI in Partnership Firm/ Proprietary Concern

NRI / PIO Other Non residents

Non repatriation

option

• Inward remittance or out of NRE/FCNR(B)/NRO account

maintained with AD Bank.

• The firm or proprietary concern is not engaged in any

agricultural/plantation or real estate business or print media

sector

Prior approval of RBI shall

be required

Repatriation option Prior approval of RBI shall be required Prior approval of RBI shall

be required

FDI in Trust

• VCF & Investment Vehicles

(including REITs, InvITs &

AIFs) – Permitted

• Other trusts – Not permitted

FDI in LLP

a) LLPs operating in sectors/activities where 100% FDI under automatic route is

allowed and there are no FDI linked performance conditions – FDI permitted

under automatic route

b) Downstream investments in (a) also allowed

c) Other cases – prior approval of the RBI

Sectoral Caps

Sector / Activity Percentage Entry Route

Agriculture and Animal Husbandry 100% Automatic

Plantation 100% Automatic

Miming 100% Automatic

Petroleum & Natural Gas – Refining by PSUs 49% Automatic

Petroleum & Natural Gas – Other 100% Automatic

Manufacturing 100% Automatic

Defence 49% Automatic

Broadcasting Carriage Services 100% Automatic

Broadcasting Content Services 49% Government

Print media 26% Government

Sectoral Caps


Civil Aviation - Airports 100% Automatic

Civil Aviation - Air transport Service – Scheduled / Regional 100% 49% Automatic

Civil Aviation - Air transport Service – Non-Scheduled & Helicopter/Seaplane 100% Automatic

Civil Aviation – Others 100% Automatic

Construction Development: Township, housing, built-up infrastructure 100% Automatic

Industrial Parks 100% Automatic

Satellites 100% Government

Private Security Agencies 74% 49% Automatic

Telecom services 100% 49% Automatic

Trading – Cash & carry Wholesale 100% Automatic

Sectoral Caps


E-commerce 100% Automatic

Single Brand Product Retail Trading 100% 49% Automatic

Multi Brand Product Retail Trading 51% Government

Duty Free Shops 100% Automatic

Railway Infrastructure 100% Automatic

Asset Reconstruction Companies 100% Automatic

Banking – Private sector 74% 49% Automatic

Banking – Public sector 20% Government

Credit Information Companies 100% Automatic

Infrastructure companies in Securities Market 49% Automatic

Sectoral Caps


Insurance 49% Automatic

Pension Sector 49% Automatic

Power Exchange 49% Automatic

White Label ATM operations 100% Automatic

NBFC 100% Automatic

Pharmaceuticals – Greenfield 100% Automatic

Pharmaceuticals – Brownfield 100% 74% Automatic

Entry Routes

1. Automatic Route - the investor or the Indian company does not require any approval from Government of India

2. Government Route - prior approval of the Government of India / FIPB in cases where:

• Indian company established with foreign investment; or

• Transfer of control / ownership to a non-resident entity as a consequence of transfer of shares and/or fresh issue of

shares through amalgamation, merger/demerger, acquisition etc.; or

Debt instruments issued to non-residents shall not be treated as foreign investment. Equity holding resulting from

conversion of debt instruments shall be reckoned as foreign investment.

Investment by NRIs and any company, trust and partnership firm incorporated outside India and owned and controlled by

NRIs deemed to be domestic investment at par with the investment made by residents

Investment Companies

• Foreign investment into an Indian company, engaged only in the activity of investing in the capital of other Indian

company/ies/ LLP, will require prior Government/FIPB approval.

• Foreign investment into Non-Banking Finance Companies (NBFCs), carrying on activities approved for FDI, will be subject

to specified conditions. Core Investment Companies (CICs), will have to additionally follow RBI’s Regulatory Framework

for CICs.

• Indian company which does not have any operations and also does not have any downstream investments, will be

permitted to have infusion of foreign investment under automatic route.

Downstream Investments

Other requirements

• Notify SIA, DIPP and FIPB of its downstream investment within 30 days of such investment

• Downstream investment in an existing Indian Company supported by a resolution of the BoD as also a SHA

Foreign Investment

Eligible Investee(India)

Indian Company /

LLP

FDI

Downstream

Investment

Comply with

relevant sectoral

conditions (entry

rotes, caps, etc.)

Pricing / valuation

guidelines

applicable on

transfer / issue of

shares

Investments acquired under

CDR, restructured loans,

defaults etc. by Banking

companies NOT CONSIDERED

foreign investment

Bring in requisite funds from

abroad and not leverage funds from

the domestic market

May raise debt in the

domestic market

Eligible Instruments

* Optionality clause allowed subject to:

a. Minimum lock-in period – 1 year from date of allotment

b. Investor exercising the option to exit without any assured returns

Instrument Equity

Shares

Preference

shares

Debentures

Non-convertible /

vanillaP *

ECB ECBOptionally convertible

NAPartially convertible

Fully and compulsorily

convertibleP * P *

Conversion of CCD / CCPS:

a. Conversion formula / price of conversion to be

fixed upfront

b. Pricing at time of conversion:

Fair value at time of issuance: X

Price Allowed / not allowed

X+ Allowed

X Allowed

X- Not allowed


Partly paid shares & Warrants

a. Conversion formula / price of conversion to be fixed

upfront

b. Consideration to be paid as follows:

c. Pricing at the time of conversion:

At least 25% upfrontBalance to paid within:

a. Partly paid shares – 12

months

b. Warrants – 18 months

Fair value at time of issuance: X

Price Allowed / not allowed

X+ Allowed

X Allowed

X- Not allowed

Other Conditions:

a. Government Route - Approval of FIPB

b. Non-payment of calls – Forfeiture

c. To ensure that sectoral caps are not breached even after

shares get fully paid-up or warrants are converted


Foreign Currency Convertible Bonds (FCCBs) and Depository Receipts(DRs)

a) FCCBs/DRs may be issued in accordance with guidelines issued in that respect.

b) A person can issue DRs, if it is eligible to issue eligible instruments to person resident outside India

c) The aggregate of eligible securities which may be issued or transferred to foreign depositories, along with eligible

securities already held by persons resident outside India, shall not exceed the limit on foreign holding of such

eligible securities under the relevant regulations framed under FEMA, 1999.

d) Pricing guidelines and Reporting requirements to be complied with

Two-way fungibility Scheme

Sponsored ADR / GDR issue

Provisions Relating to Issue

Issue price of shares: Not less than –

a. Listed shares – as per SEBI guidelines

b. Unlisted shares - Fair value of shares (done by Merchant Banker / CA as per any internationally accepted pricing

methodology on arm’s length basis); and

c. Preferential allotment - Price as applicable to transfer of shares from resident to non-resident as per RBI guidelines

d. Subscription to MOA - May be made at face value

Inward remittance / Debit to NRE/FCNR(B) a/c *

Allotment of capital instrumentsOR

Refund to non-resident investor

Within 180 days

* Amount may be retained in Foreign currency with RBI approval

Provisions Relating to Transfer

Transferor Transferee Sale Gift

Non-resident Non-resident P P

Non-resident NRI P P

NRI NRI P P

NRI Non-resident RBI approval RBI approval

Non-resident Resident P P

Resident Non-resident P RBI approval

General permission for transfer

The transfer is subject to the following conditions:

- Company being in a sector under Automatic route

- Compliance with pricing guidelines

Provisions Relating to Transfer

Transfer which requires Government approval:

i. Sectors under Government approval route

ii. Breach of sectoral caps

Transfer which requires approval of the RBI:

i. Transfer from resident to non-resident by way of sale, where payment of consideration is deferred

ii. Gifting of shares from a resident to non-resident

iii. Transfer of shares from NRI to non-resident

iv. Transfer of shares from and to erstwhile OCBs

v. Cases where pricing guidelines are not complied with

Conversion of ECB/ Lump sum Fee into Equity

General permission for issue of equity shares / CCD / CCPS against:

• ECB (excluding deemed ECB) in convertible foreign currency

• ECB under Automatic or Government route

• Whether due for payment or not

• Includes secured / unsecured loans from non-resident collaborators

• Lump sum technical know-how fee & royalty (conversion to be net of applicable taxes)

• Import of capital goods/ machinery / equipment (excluding second-hand machinery)

• Pre-operative / pre-incorporation expenses (including payment of rent)

Rights / Bonus Shares

• Issue of Rights/ Bonus shares to existing non-resident shareholders allowed, subject to sectoral cap and compliance

with applicable statutory requirements

• Offer price for rights issue:

• Listed company - price determined by the company

• Unlisted company - not less than the offer price for resident shareholders

• Additional allocation of rights share by residents to non-residents

• out of the unsubscribed portion

• overall issue of shares to non-residents does not exceed the sectoral cap

• Rights / Bonus issue to erstwhile OCBs

• Rights issue – RBI approval required

• Bonus issue – general permission

M&A, ESOPs, Share swap

Acquisition of Shares under a court approved Scheme of Merger/Demerger/Amalgamation

• Sectoral cap not breached

• Transferor/Transferee company is not engaged in activities which are prohibited under FDI policy

• Bonus issue of Non convertible / redeemable preference shares or debentures

• distribution as bonus from its general reserves under a court approved Scheme of Arrangement

• subject to no-objection from the Income Tax Authorities.

Issue of ESOPs / Sweat Equity

• Scheme as per SEBI regulations / Corporate laws, as applicable

• Sectoral cap not breached

• FIPB approval – sectors under the approval route & issue of shares to Citizen of Pakistan / Bangladesh

Share Swap

• Valuation of shares by a Merchant Banker

• Government approval required for sectors under Government route.

Pledge of Shares

Pledge of Shares

• A person being a promoter of a company registered in India, which has raised ECB can pledge the shares of the

borrowing company or its associate resident companies for securing the ECB raised by the borrowing company provided

no objection obtained from a AD Bank.

• Pledge would be subject to the following conditions:

• Period of the pledge shall be co-terminus with the maturity of underlying ECB

• In case of invocation of pledge, transfer shall be as per FDI policy & directions issued by RBI

• Statutory auditor has certified that the borrowing company will /has utilized the proceeds of the ECB for the

permitted end use only.

Repatriation and Remittance

Remittance of Sale proceeds

a. Remittance made net of applicable taxes

b. Security sold is held on repatriation basis

c. Sale is in accordance with prescribed guidelines

d. NOC / Tax clearance certificate

Remittance of proceeds of liquidation / winding up

a. NOC / Tax clearance certificate

b. Auditors certificate (concerning provision for liabilities, compliances, etc)

Repatriation of Dividends / Interest

a. Repatriation to be net of TDS / DDT

b. Considered as a Current account transaction

Calculation of Direct & Indirect FDI

Direct Investment

All investment by non-resident shall be counted towards foreign investment

Indirect Investment

Considered as Domestic Investment Considered as Foreign Investment

Investing Company/LLP ‘owned and controlled’ by

residents/Indian Companies/LLPs Investing Company is ‘owned or controlled’ by non-

resident entitiesDownstream investment by Investment Vehicles*

* If either the Sponsor or Manager or Investment Manager is Indian ‘owned and controlled’

F.Co 1

I.Co 1

I.Co 2

49%

80%

F.Co 1

I.Co 1

I.Co 2

51%

80%

F.Co 1

I.Co 1

I.Co 2

75%

60%

F.Co 1

I.Co 1

I.Co 2

75%

100%

Taxation – Indirect Transfer

F.Co 1

F.Co 2

I.Co

F.Co 3

Taxable if:

• Value of assets in India > INR 10 Cr

• Value of assets in India > 50% of value of

all assets of F.Co 2

Note: The term ‘value’ means fair market value of

assets as determined under new Rule 11UB of

Income Tax Rules, 1962

Capital Gains taxable in India:

Gains on transfer

Value of ASSETS in India

India

Overseas

Value of all ASSETS of F.Co 2

X

As per Rule 11UC of Income Tax Rules, 1962

THANK YOU

training presentation - lo,bo,po,fdi

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