Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Voluntary compensation for diminution in the value of unexercised employee stock options following corporate restructuring is not taxable as a perquisite or salary where it is not contractually or statutorily required, is paid without exercise, allotment, transfer, surrender, cancellation or repurchase of the options, and the employee retains the options. The proximate cause is the restructuring rather than employment. Payer-side tax deduction or Form 16 classification cannot create a tax charge absent satisfaction of the charging provisions. The payment also cannot be treated as profits in lieu of salary merely through an alternative salary provision.
Voluntary compensation for diminution in the value of unexercised employee stock options following corporate restructuring is not taxable as a perquisite or salary where it is not contractually or statutorily required, is paid without exercise, allotment, transfer, surrender, cancellation or repurchase of the options, and the employee retains the options. The proximate cause is the restructuring rather than employment. Payer-side tax deduction or Form 16 classification cannot create a tax charge absent satisfaction of the charging provisions. The payment also cannot be treated as profits in lieu of salary merely through an alternative salary provision.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
