SIFMA, ASIFMA, and 9 other associations submit comments to India’s Department of Revenue on the Draft Report on Retrospective Amendments Relating to Indirect Transfer released by the Expert Committee chaired by Dr. Parthasarathi Shome.  The groups believe proposed provisions in the Finance Bill 2012 relating to the taxation of indirect transfers, including their retrospective effect, deviate so significantly from prevailing international policy and practice and create such substantial doubt about India’s commitment to fair treatment and the rule of law that they would have a real and lasting negative impact on the attractiveness of India as an investment location.