Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Page of 4778
Press 'Enter' after typing page number.
61 to 80 of 95557 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4778
Join Channel
TaxTMI 
