S. 197 : Deduction at source-Certificate for lower rate-Stock options-Salaries-Specified security-Property-Since the assessee did not make any payment towards the ESOPs and continues to retain all the ESOPs even after the receipt of compensation, the entire receipt qualifies as the perquisite and becomes liable to be taxed under the head “Salaries”-Assessee is not entitled to a ‘nil’ certificate of deduction [S.2(14), 15, 17(2), 192,, Sale of Goods Act, 1930, Companies Act, 2013, Art. 226 ]