文档介绍：MAT: Retrospective Tax Is Back? There exists proverb in English “ Once bitten, twice shy ”. This proverb doesn ’t hold well in case of Indian tax system. After facing the Backlash from the international investors in case of Vodafone retrospective case which resulted in vitiating economic environment. Since that judgment, there has been constant assurance made by Mr. P. Chidambaram, former Finance Minister, and present NDA government to foreign investors for ensuring stable Tax regime with no retrospective tax in future. One can never know when e tax officials (Herein after referred as“ Revenue ”) comes back to haunt assessee. Issue Castleton Investment Limited (CIL), a Mauritius entity, owned shares of Glaxo Smithkline India, since 1993. It wanted to transfer these shares toa Singaporean group entity Glaxo Smithkline Pharmaceuticals Limited (“ GSPL ”) as part of restructuring exercise. Entity had been in possession of shares for more than 20 years and proposes to transfer the share for cash consideration at“ Fair Market Value ”. CIL filed an application seeking view on whether Section 112 is applicable in case of MAT provisions. AAR came up with judgment in favor of revenue and held that MAT provisions scope was wide to cover panies including panies. It does not make any difference whether or not PE exists or not. Department after 3 years from above ruling came up with the dema