Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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).
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