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2005 (3) TMI 23 - AUTHORITY FOR ADVANCE RULINGSNon-resident – holds shares of non-resident US company - under the stock purchase agreement there is no element of contingent payment, the entire consideration is to be paid by the closing date - Gains arising to the applicant from the transfer those shares are chargeable to tax under the head "Capital gains" - Contingent payments received/receivable by the applicant would fall within the meaning of profits in lieu of or in addition to salary under clause (3) (ii) of section 17
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