On 9 March 2017, the Delhi Income Tax Appellate Tribunal gave its decision on a case involving a retroactive capital gains tax assessment resulting from changes made by the Finance Act 2012 to the Income Tax Act, 1962 (ITA) regarding the taxation of indirect transfers. The Finance Act 2012 added an explanation to the ITA to clarify that any share or interest in a company or entity registered or incorporated outside India is deemed to be situated in India, if the share or interest derives, dir…