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...
The compensation received by the petitioner for diminution in value of ESOPs is a perquisite taxable under the Income-tax Act, 1961, not a capital receipt. To determine the value of the perquisite, the benefit received by the employee from the specified security should be ascertained. Since no payment was made by the petitioner towards ESOPs and the ESOPs continue to be retained, the entire compensation received qualifies as a perquisite liable to be taxed under the head "salaries". The petitioner is not entitled to a 'nil' certificate of deduction of tax at source. Although the basis for the conclusion in the impugned order is flawed, the rejection of the request for a 'nil' certificate is affirmed.
The compensation received by the petitioner for diminution in value of ESOPs is a perquisite taxable under the Income-tax Act, 1961, not a capital receipt. To determine the value of the perquisite, the benefit received by the employee from the specified security should be ascertained. Since no payment was made by the petitioner towards ESOPs and the ESOPs continue to be retained, the entire compensation received qualifies as a perquisite liable to be taxed under the head "salaries". The petitioner is not entitled to a 'nil' certificate of deduction of tax at source. Although the basis for the conclusion in the impugned order is flawed, the rejection of the request for a 'nil' certificate is affirmed.
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