05 Jul 2026


This is a link-enhanced version of an article that first appeared in The Economic Times.
Article Overview:
The article examines the Income Tax Department’s issuance of reassessment notices to several foreign investors despite them not earning any income from their investments. It explores the concerns surrounding the reopening of transactions involving only the purchase of Indian shares and the broader implications for foreign investors, tax compliance and regulatory certainty.
Our Partner, Aditi Goyal, shared her perspective. Here’s what she had to say:
“What’s striking is that several notices relate to purchase transactions, and not exits. Here, a non-resident merely acquired Indian shares and has not earned any income from the transaction. It’s probably triggered by the absence of I-T Return by these investors along with information from remittance documents. This is difficult to justify: a share purchase by a non-resident does not, by itself, result in income and there was no obligation to file ITR. A reassessment regime meant to tax escaped income should not be used to question a transaction which produced no income in the first place.”
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