Taxation of VISA Inc. Share Allotment: Notional Share Price Not Taxable as Benefit u/s 28(iv) of Income Tax Act.

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....Taxing the allotment of shares by VISA Inc. by invoking Section 28(iv) - bringing notional share price to tax - the word used in Section 28(iv) of the Act are ‘arisen from business’ where ‘arisen’ signifies that benefit itself must have arisen. It was held that mere issuance of shares does not result in any benefit.....