“Substantial” Light on Indirect Transfer Provisions

The 2015 Union Budget of India which was presented on 28 February 2015 announced several changes to the indirect transfer provisions in the income tax legislation, specifically by inserting Explanations 6 and 7 to section 9(1)(i) of the Income Tax Act 1961 effective from the financial year 1 April 2015, which have since been enacted. This article elaborates on the amendments and their impact on the future treatment of indirect transfers in India, as well as areas that may require further consideration.