(viib) where a company, not being a company in which the public are substantially interested, receives, in any previous year, from any person being a resident, any consideration for issue of shares that exceeds the face value of such shares, the aggregate consideration received for such shares as exceeds the fair market value of the shares: (2) In particular, and without prejudice to the generality of the provisions of Sub-section (1), the following incomes, shall be chargeable to income-tax under the head “Income from other sources”, namely:. (1) Income of every kind which is not to be excluded from the total income under this Act shall be chargeable to income-tax under the head “Income from other sources”, if it is not chargeable to income-tax under any of the heads specified in Section 14, items A to E. RELATED PROVISIONS IN THE INCOME TAX ACT AND INCOME TAX RULEĥ6. The relevant portion of law is reproduced below. In this article,we will look into the legal issues in invoking the provisions of Sec 56(2)(viib) of Income Tax Act 1961. The AO can verify the source of the subscription and also can apply the yardstick of Sec 56(2)(viib) of Income Tax Act 1961. Subscription received with huge premium, is a common issue in company assessments.
The assessment of share premium is always a contentious issue. Towards the end, the issue of angel tax which occupied quite a space in the public discourse till recently, has also been touched upon. Several case laws on the issue has been presented for better appreciation by the readers. the route of Section 68 or Section 56 (2)(viib). This article examines the two alternative approaches the AO should adopt while examining the issue where share premium received is in excess of its fair market value, i.e. Taxation of share premium is a relatively new but litigated area of taxation.
WRITEDOWN IN PREMIUM MANUAL
Was Member of contributors for “Investigation Manual” and TPO manual on “Financial Transactions”. Received appreciation letters for Contribution in TDS as well as DTRTI, Kolkata. Regular visiting faculty of DTRTI, Kolkata and Visiting Sr. The company said it would book the latest charge in the fiscal third quarter and is examining how that will affect its forecasts.More than 25 year of experience as an officer of Income Tax Department in various departments including Investigation, Central ,Corporate ,TDS and Transfer Pricing charges.
WRITEDOWN IN PREMIUM TV
Since then, he has led a restructuring to focus on games, financial services and content that has included the company exiting personal computers and separating its TV manufacturing unit into a new division. “We think this is the new management owning up the mistakes of Sony’s past."Īfter chief financial officer Kenichiro Yoshida took over in 2014, he said Sony had revised earnings forecast more than a dozen times in seven years. He reiterated his buy rating on the stock. “There are many investors who have not forgotten how Sony in past repeatedly over-promised and under-delivered," Atul Goyal, an analyst at Jefferies Group, wrote in a report. The writedown announcement comes two weeks after Sony said the chief executive officer of Sony Entertainment, Michael Lynton, is stepping down after a 13-year run.
WRITEDOWN IN PREMIUM MOVIE
The studio has struggled recently, including with last year’s Ghostbusters sequel and a movie based on the Angry Birds video game. In June, Sony warned the movie division was at a risk of posting more losses.
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