This article analyses the recent judgment of the High Court of Judicature at Bombay (the High Court) in the case of Aditya Birla Nuvo Limited and Others, the core issue was whether any income chargeable to tax in India accrued or arose, or is deemed to have accrued or arisen in India to a US company upon the sale of shares held by or of a “permitted transferee” of another US company.