India's High Court in Bombay recently ruled on whether or not the issuance of shares by Royal Dutch Shell's Indian unit to its parent company based in the Netherlands gives rise to Indian tax and subject to the country's transfer pricing rules. The ruling follows a ruling on a similar case in October 2014 where the High Court ruled in favor of Vodafone.
The Royal Dutch Shell case involved a 2009 issuance of shares by Shell India Markets Pvt. Ltd. to its parent company Shell Gas BV. The India…