The assessee was a former employee of a company that was part of a Singapore‑based group which had granted employee stock options. The assessee was granted 127,552 options under a vesting schedule. After a disinvestment announced on December 23, 2022, the value of the options fell and, on April 21, 2023, the Singapore company made a one‑time voluntary payment of USD 43.67 per option to option‑holders as compensation for loss in value. The company stated it would withhold tax. The assessee applied under section 197 for a nil deduction certificate; the application was rejected by the Department treating the payment as a perquisite under section 17(2)(vi). On writ: the court held that the options had not been exercised and no contingency in section 17(2)(vi) had occurred; the payment was voluntary and not a statutory or contractual transfer by the employer linked to employment; hence, it was not a perquisite and not chargeable to tax. The rejection was invalid; the assessee was given liberty to apply for refund of TDS.