Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The HC allowed the petitioner's writ petition seeking a Nil Tax Deduction Certificate under Section 197 for compensation received due to diminution in value of Flipkart Stock Options Plan (FSOP). The petitioner, an employee of an Indian subsidiary, received one-time compensatory payment without exercising stock options or receiving share allotment. The Court held that FSOPs become taxable only when options are exercised (as perquisites under Section 17(2)(vi)) or when allotted shares are sold (as capital gains under Section 45). Since neither event occurred, the voluntary compensatory payment constituted a capital receipt not chargeable under any income head. Following precedent in similar Flipkart employee cases, the Court quashed the rejection order and directed respondents to issue the Nil Tax Deduction Certificate within six weeks.
The HC allowed the petitioner's writ petition seeking a Nil Tax Deduction Certificate under Section 197 for compensation received due to diminution in value of Flipkart Stock Options Plan (FSOP). The petitioner, an employee of an Indian subsidiary, received one-time compensatory payment without exercising stock options or receiving share allotment. The Court held that FSOPs become taxable only when options are exercised (as perquisites under Section 17(2)(vi)) or when allotted shares are sold (as capital gains under Section 45). Since neither event occurred, the voluntary compensatory payment constituted a capital receipt not chargeable under any income head. Following precedent in similar Flipkart employee cases, the Court quashed the rejection order and directed respondents to issue the Nil Tax Deduction Certificate within six weeks.
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