WABCO INDIA LIMITED, REP BY ITS CHIEF FINANCIAL OFFICER, R S RAJA GOPAL SASTRY Vs. DEPUTY COMMISSIONER OF INCOME-TAX

JUDGEMENT

(1.) This intra-court appeal is against an order dated 20.03.2018 passed by the learned Single Bench dismissing W.P.No.1649 of 2018 filed by the appellant challenging a show cause notice issued to the appellant under Section 163 (1)(c) of the Income Tax Act, 1961, (in short 'the IT Act').

(2.) The appellant incorporated under the Companies Act, 1956, in the year 1962, is engaged in the business of designing, manufacturing and marketing conventional braking products, advance braking systems and other related air assisted products and systems. The company is duly listed in the Stock Exchange and its shares are transferable.

(3.) In 2012-13, 75% of the shares of the appellant were held by Clayton Dewandre Holdings Ltd., hereinafter referred to as 'Clayton Dewandre' and the balance 25% held by the public. In 2013-14, Clayton Dewandre transferred its entire shareholding to WABCO Asia Private Limited, Singapore, hereinafter referred to as 'WABCO, Singapore'.