Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Section 49(2AA) treats the fair market value used to value an ESOP perquisite under section 17(2)(vi) as the cost of acquisition for capital gains purposes, without requiring that the perquisite be included in taxable income or taxed in India. Perquisite valuation and its taxability under domestic charging provisions or an applicable treaty operate independently. Taxation of the related perquisite in the United Kingdom does not prevent use of the statutory fair market value as the ESOP share cost. Capital gains were to be recomputed using the fair market value determined under section 17(2)(vi) read with Rule 3(8)(ii).
Section 49(2AA) treats the fair market value used to value an ESOP perquisite under section 17(2)(vi) as the cost of acquisition for capital gains purposes, without requiring that the perquisite be included in taxable income or taxed in India. Perquisite valuation and its taxability under domestic charging provisions or an applicable treaty operate independently. Taxation of the related perquisite in the United Kingdom does not prevent use of the statutory fair market value as the ESOP share cost. Capital gains were to be recomputed using the fair market value determined under section 17(2)(vi) read with Rule 3(8)(ii).
Note: It is a system-generated summary and is for quick reference only.