respect of discount offered to the
employees on allotment of shares of the parent company, viz.,
NIIT Technologies Ltd. under a Employees Stock Option Plan ... parent company. The CIT(A) also found that though the
shares of the parent company have been allotted, the same
20
ITA No.3077
shares, which is 24%, @ Rs. 23.10 per share for a
consideration of Rs. 49,43,40,000/-. The capital gains arising on sale of shares ... demerger as the demerged company's shares are
directly distributed to the "parent" company's shareholders.
Capital and Financial Restructuring
This
parent company, have been
allotted to the employees of ASPL and not to the employees of
the parent company. Though the shares of the parent ... entire share
price of the shares allotted. Further, such shares have not
been issued out of the share capital of the appellant and
hence cannot
Adobe
Systems India Pvt. Ltd., Noida has given the ESOP - shares of its
parent company M/s Adobe Systems Inc., USA under Cashless
Exercise Option ... Adobe Systems India
Pvt. Ltd was offered shares of parent company under various
schemes including ESOP scheme. This offer is given at the time
fact that the ESOP scheme provides for
grant of shares of the parent company, the value/ discount
thereof is reimbursed/ recouped by the appellant inasmuch ... allowable since the
ESOPs are granted to acquire shares of the parent company is
patently erroneous and not sustainable. Being so, the
disallowance of ESOP
less on account of the share premium while issuing shares
to its parent holding company. On these basis an adjustment ... assessee company had received amounts on account of share premium
while issuing share to its parent holding company. However, subsequently, the
Ld. Departmental Representative
juridical structure of the parent
company itself, such as meetings of shareholders of the parent,
issuing of shares in the parent company and costs ... juridical structure of the parent Company (like shareholder meetings,
issuing of shares in parent Company etc.), consolidation of financial
statements for reporting purposes, etc. These
allowed by the Reserve Bank of India. The said allotment of
shares to parent company does not qualify as 'international transaction' defined ... leviable. In any case, allotment of shares to
parent company does not fall within the meaning of international transaction as
defined under the Act, hence
shall levy or collect any donation compulsorily from any student or any parent or guardian of any student.
(2) No aided school shall collect ... case, there is no way out but for the parents to share the cost of such developments.
24. It does not need any detailed deliberation
essentially in the nature of
share-holders/stewardship services which are for the benefit of the parent
company and hence to that extent ... ESOP") exercised by BGEPIL employees. BGEPIL employees
receive shares from the parent company as Stock Options.
These shares are allotted
