Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
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ESOP expenditure was held allowable as a deduction under section 37(1) because the jurisdictional Karnataka High Court had already decided the issue in favour of the assessee and upheld deletion of the disallowance in the assessee's own case. Mere pendency of a similar issue before the Supreme Court in another matter did not dilute the binding effect of that High Court ruling. Applying the jurisdictional precedent, the Tribunal rejected the Revenue's challenge and sustained the deletion of the ESOP disallowance.
ESOP expenditure was held allowable as a deduction under section 37(1) because the jurisdictional Karnataka High Court had already decided the issue in favour of the assessee and upheld deletion of the disallowance in the assessee's own case. Mere pendency of a similar issue before the Supreme Court in another matter did not dilute the binding effect of that High Court ruling. Applying the jurisdictional precedent, the Tribunal rejected the Revenue's challenge and sustained the deletion of the ESOP disallowance.
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