Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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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