https://www.taxtmi.com/caselaws?id=6584 The court held that the gains from the transfer of 15,000 shares are chargeable to capital gains tax based on the fixed amount received. The initial lump sum payment of $2.3 million constitutes the full consideration for the share transfer and is taxable in the assessment year 2004-05. Contingent payments tied to performance under an employment agreement are taxable as salaries in the respective years received. The court did not address relief under the Double Taxation Avoidance Agreement as it was not pursued by the applicant. en-us Wed, 30 Mar 2005 00:00:00 +0530 Thu, 15 Jan 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6584 The court held that the gains from the transfer of 15,000 shares are chargeable to capital gains tax based on the fixed amount received. The initial lump sum payment of $2.3 million constitutes the full consideration for the share transfer and is taxable in the assessment year 2004-05. Contingent payments tied to performance under an employment agreement are taxable as salaries in the respective years received. The court did not address relief under the Double Taxation Avoidance Agreement as it was not pursued by the applicant. Case-Laws Income Tax Wed, 30 Mar 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6584