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(3) Total amount received till AY 2017-18 as option price is Rs.2480.48 crore.

(4) Whatever may be "Market Price" of "Aviva" shares, as per the table, money retained by PIC is always more than "Option price"

received i.e. option price received is Rs.2480.48 crore and money retained in these 4 different market values is Rs.6321.20 crore (when Rs.100/- MV per share) and Rs.2941.60 crore in rest of three cases is same whether market value of shares is 0 or 10 or 20.38 per share. This means option price is never refunded. (5) This means there is guaranteed minimum return of Rs.2914.60 crore to PIC from CUIH on such money applied, irrespective of market value of shares, even when market value is zero.

37. The ld. DR further highlighted on the following points"

1. Option price is a recurring annual receipt which is taxable in the year of receipt. As per schedule 1 of J.V. Agreement, assessee is receiving annually 20% as a fixed return on investment from FDI Partner (CUIH) as per clause 16.6.2 of J.V. Agreement. As per table given separately, minimum fixed annual return is received by the assessee even if market value of Aviva share is 'zero'.