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Income Tax - Highlights / Catch Notes

Home Highlights May 2016 Year 2016 This

Issue of shares at a premium by the petitioners to its non ...

Income Tax

May 2, 2016

Issue of shares at a premium by the petitioners to its non -resident holding company does not give rise to any international transaction, that in such a case application of the provisions of Chapter X of the Act would not arise - AT

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  1. 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...

  2. 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 –...

  3. Additions u/s 40(a)(i) for non deduction of TDS - The assessee has to necessarily deduct tax on the premium paid to non-resident re-insurance company for reinsurance.

  4. 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,...

  5. Addition u/s 68 - share capital and share premium - allegation regarding identity and creditworthiness - non appearance of director - addition cannot be sustained merely...

  6. 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...

  7. TDS u/s 195 - payments made to non-resident - The amounts paid by resident Indian endusers/ distributors to non-resident computer software manufacturers/suppliers, as...

  8. Revision u/s 263 - Right issue shares - applicability of section 56(2)(viib) on the issue of shares by the company by stating that this section applied only to the...

  9. Addition u/s 56(2)(vii) on account of alleged excess share premium - AO on account of alleged excess share premium is unjustified when those very shares are sold in next...

  10. Disallowance u/s 56(2)(viib) - issuance of shares with premium - share application money was received by the company from a non-resident company - since provisions of...

 

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