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        Rule 11 - Fair market value of assets in certain cases

        Income-Tax Rules, 2026

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        Fair market value valuation rules for foreign-held assets set detailed methods for listed shares, unlisted shares, and partnership interests. Fair market value of assets held directly or indirectly by a foreign company or entity for the purposes of section 9(10) is to be computed with reference to the specified date under a structured valuation framework. Listed shares of an Indian company are valued at observable stock exchange price, subject to a prescribed market-capitalisation based formula where the holding confers management or control rights, and with reference to the exchange recording the highest trading volume where the share is listed on more than one exchange. Unlisted shares of an Indian company are valued by a merchant banker or accountant using internationally accepted valuation methodology on an arm's length basis, with liabilities added back. Interests in a partnership firm or association of persons are valued by first determining the entity value on an internationally accepted basis, then allocating capital and residual value according to contribution ratios, dissolution arrangements, or profit-sharing ratios, as applicable.
                    Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                      Provisions expressly mentioned in the judgment/order text.

                          Fair market value valuation rules for foreign-held assets set detailed methods for listed shares, unlisted shares, and partnership interests.

                          Fair market value of assets held directly or indirectly by a foreign company or entity for the purposes of section 9(10) is to be computed with reference to the specified date under a structured valuation framework. Listed shares of an Indian company are valued at observable stock exchange price, subject to a prescribed market-capitalisation based formula where the holding confers management or control rights, and with reference to the exchange recording the highest trading volume where the share is listed on more than one exchange. Unlisted shares of an Indian company are valued by a merchant banker or accountant using internationally accepted valuation methodology on an arm's length basis, with liabilities added back. Interests in a partnership firm or association of persons are valued by first determining the entity value on an internationally accepted basis, then allocating capital and residual value according to contribution ratios, dissolution arrangements, or profit-sharing ratios, as applicable.





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