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Applicabilioty of TDS on reversing of share applicaitonmoney

This query is : Resolved 
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(Querist)
03 February 2010 Dear all,

One of our clients has got some share application money from their US holding company in multiple installments.
Recently, the Indian subsidiary ownership is changed and two more local companies have bought shares and eventually become majority shareholders. In this regard, the share application money invested by US company is now being returned to that company. Please clarify if TDS is applicable on this remittance?
regards,
Sriniwas VN.
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CA Vijay Kumar Gupta

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CA Vijay Kumar Gupta (Expert)
03 February 2010 in my opinion, as no income is chargeable on this transaction under The I. Tax Act,1961, no need to deduct tds u/s 195.
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sriniwas

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sriniwas (Querist)
03 February 2010 Thank you very much Sir.
regards,
VN Sriniwas
ACA
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