Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Page of 4809
Press 'Enter' after typing page number.
5201 to 5220 of 96177 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
No transfer pricing adjustment could be sustained on the notional value of employee stock options granted by a parent company to the assessee's employees, because the assessee had not actually incurred any expenditure or assumed any liability for acquiring the shares. The Tribunal applied Rule 10B(1)(e)(i) and held that net profit margin under TNMM must be computed with reference to costs actually incurred, meaning a real financial outflow or obligation. Since the TDS reimbursement was made without mark-up and no ESOP cost was recorded in the books, imputation of a hypothetical cost was contrary to the transfer pricing rules. The adjustment relating to Restricted Stock Units was deleted.
No transfer pricing adjustment could be sustained on the notional value of employee stock options granted by a parent company to the assessee's employees, because the assessee had not actually incurred any expenditure or assumed any liability for acquiring the shares. The Tribunal applied Rule 10B(1)(e)(i) and held that net profit margin under TNMM must be computed with reference to costs actually incurred, meaning a real financial outflow or obligation. Since the TDS reimbursement was made without mark-up and no ESOP cost was recorded in the books, imputation of a hypothetical cost was contrary to the transfer pricing rules. The adjustment relating to Restricted Stock Units was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
