Sterling Holiday Resorts Ltd. v. Dy. CIT (2025) 127 ITR 284 / 180 taxmann.com 310 (Mum.)(Trib.)

S. 37(1): Business expenditure-Employees’ Stock Option Plan-Discount on issue of shares-Expenditure allowable.

The Tribunal followed its earlier orders in the assessee’s own case and held that the Employees’ Stock Option Plan expenditure, representing the difference between the fair market value and the issue price of shares and accounted for in accordance with the SEBI Guidelines, constituted an allowable business expenditure. The Assessing Officer was directed to delete the disallowance. (AY. 2018-19).

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