Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Consideration received on repurchase of vested but unexercised employee stock options is characterised as long-term capital gains rather than a salary perquisite. Section 17(2)(vi) applies to specified securities allotted or transferred by an employer and requires valuation upon exercise of the option. An unexercised option is only a right to subscribe for shares; where no option is exercised and no shares are allotted, no specified security arises and no taxable perquisite can be valued. The right is a capital asset, and its repurchase is a transfer. Form 16, TDS and indicative tax statements cannot determine liability contrary to law.
Consideration received on repurchase of vested but unexercised employee stock options is characterised as long-term capital gains rather than a salary perquisite. Section 17(2)(vi) applies to specified securities allotted or transferred by an employer and requires valuation upon exercise of the option. An unexercised option is only a right to subscribe for shares; where no option is exercised and no shares are allotted, no specified security arises and no taxable perquisite can be valued. The right is a capital asset, and its repurchase is a transfer. Form 16, TDS and indicative tax statements cannot determine liability contrary to law.
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