TPA - issue of shares at a premium by the Petitioner to its non ...

Shares Issued at Premium to Non-Resident Parent Not Taxed as Income; Chapter X Inapplicable.

October 12, 2014

Case Laws Income Tax HC

TPA - issue of shares at a premium by the Petitioner to its non resident holding company does not give rise to any income from an admitted International Transaction – there is no occasion to apply Chapter X of the Act - HC

View Source

← Previous Next →

TPA - issue of shares at a premium by the Petitioner to its non ...

Shares Issued at Premium to Non-Resident Parent Not Taxed as Income; Chapter X Inapplicable.

October 12, 2014

Case Laws Income Tax HC

You may also like:

Application of Chapter X - Transfer pricing adjustments - Issue of shares at premium by the Petitioner to its non-resident holding company does not give rise to income...

Correct head of income - sale consideration received by the assessee from redemption of preference shares including the premium- capital income or income from other...

Addition made on share premium u/s.68 - share premium received from its holding companies namely situated at Hongkong, who are non resident entities - the said share...

TDS u/s 195 - payment made to its parent company - Although, the assessee strongly relied upon the certificate issued by the Deloitte GmbH and contended that the payment...

This case deals with the issue of whether GST/service tax amount should be included while computing the gross receipts u/s 44BB for a non-resident company engaged in...

Unexplained share capital and share premium - Not only the assessee has proved the identity and creditworthiness of the investors and genuineness of the transactions by...

As decided in Total Oil India (P.) Ltd., where a domestic company declares, distributes or pays dividend to a non-resident shareholder(s), the Additional Income-tax (Tax...

Additions u/s 56(2)(viib) - issuance of shares less than fair market value - the shares have been subscribed at face value and there is no premium whatsoever - further,...

Disallowance of ESOP expenses - in terms of ESOP if an assessee offers shares of its parent company to its employees the difference between the FMV of the shares of the...

The appellant qualified as a non-resident in India during the previous year 2015-16. A non-resident is taxable in India only for income received/deemed to be received or...

Revision u/s 264 - Claiming benefit of DTAA - refund of Dividend Distribution Tax (DDT) which was paid wrongly - This was not a case where a deduction was made u/s 195...

Rate of TDS - Non-availability of PAN - Benefit of treaty - in case of payments made to non-residents, the assessee was entitled to deduct taxes at source at the rates...

ITAT allowed taxpayer's appeal regarding Tax Collected at Source (TCS) credit for minor child's income clubbed with parent's income. While statutory amendment permitting...

The High Court examined the jurisdiction of the Assessing Officer (AO) and the prescribed income-tax authority to issue notices u/s 143(2) of the Income Tax Act. It held...

Rate of tax payable on Dividend Distribution Tax (DDT) - Distribution of dividends to its share holders (Germany) (Non-residents) - the additional income tax payable by...

Quick Updates: