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 rules prescribe valuation methods and apportionment for assets held by foreign companies and entities. Determination of fair market value for assets held by foreign companies or entities under rule 11UB requires listed Indian shares to be valued at the observable stock exchange price except where management or control rights exist, in which case a (market capitalisation + book liabilities)/outstanding shares formula applies; unlisted shares and other assets must be valued by a merchant banker or accountant using internationally accepted methodologies with liabilities added as considered; aggregation formulas govern valuation of all assets for transfers between non-connected persons and other transfer situations.
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Provisions expressly mentioned in the judgment/order text.
Fair market value rules prescribe valuation methods and apportionment for assets held by foreign companies and entities.
Determination of fair market value for assets held by foreign companies or entities under rule 11UB requires listed Indian shares to be valued at the observable stock exchange price except where management or control rights exist, in which case a (market capitalisation + book liabilities)/outstanding shares formula applies; unlisted shares and other assets must be valued by a merchant banker or accountant using internationally accepted methodologies with liabilities added as considered; aggregation formulas govern valuation of all assets for transfers between non-connected persons and other transfer situations.
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