Part DCA - Safe Harbour Rules for income referred to in clause (i) of sub-section (1) of section 9 chargeable to tax under the head (From Rule 10TI to Rule 10TIC)
Fair market value of foreign entity assets follows prescribed valuation methods for shares, partnerships, and other assets. Rule 11UB prescribes methods for determining the fair market value of assets held directly or indirectly by a foreign company or foreign entity for section 9(1). It sets separate valuation rules for listed and unlisted Indian shares, interests in partnership firms or associations of persons, other assets, and all assets of a foreign company or entity. The rule also provides for use of observable price, internationally accepted valuation methodology, allocation of value among partners or members, exchange-rate conversion, and revisions after finalisation of the relevant financial statement.
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Provisions expressly mentioned in the judgment/order text.
Fair market value of foreign entity assets follows prescribed valuation methods for shares, partnerships, and other assets.
Rule 11UB prescribes methods for determining the fair market value of assets held directly or indirectly by a foreign company or foreign entity for section 9(1). It sets separate valuation rules for listed and unlisted Indian shares, interests in partnership firms or associations of persons, other assets, and all assets of a foreign company or entity. The rule also provides for use of observable price, internationally accepted valuation methodology, allocation of value among partners or members, exchange-rate conversion, and revisions after finalisation of the relevant financial statement.
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