Share premium classified as capital, not income, and not subject to transfer pricing adjustment; adherence required. Share premium on issue of shares is a capital account transaction and does not give rise to income for transfer pricing purposes. The Board has accepted this ratio and directs field officers to follow it in all cases where the issue arises, and to communicate the position to appellate and dispute-resolution bodies to ensure consistent application.
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.
Share premium classified as capital, not income, and not subject to transfer pricing adjustment; adherence required.
Share premium on issue of shares is a capital account transaction and does not give rise to income for transfer pricing purposes. The Board has accepted this ratio and directs field officers to follow it in all cases where the issue arises, and to communicate the position to appellate and dispute-resolution bodies to ensure consistent application.
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