https://www.taxtmi.com/caselaws?id=239041 The dominant issue was whether discount/expenditure arising from an ESOP is deductible as revenue expenditure under s. 37(1) of the Act or is capital in nature. Relying on the ITAT (SB) ruling that ESOP discount represents employee compensation incurred wholly and exclusively for business purposes, the Tribunal held that any incidental benefit to the parent entity from a motivated workforce does not negate the assessee's business purpose or s. 37(1) conditions. The ESOP expenditure was therefore treated as revenue expenditure and allowed as a deduction while computing income, resulting in relief to the assessee. en-us Mon, 30 Sep 2013 00:00:00 +0530 Fri, 02 Jan 2026 11:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239041 The dominant issue was whether discount/expenditure arising from an ESOP is deductible as revenue expenditure under s. 37(1) of the Act or is capital in nature. Relying on the ITAT (SB) ruling that ESOP discount represents employee compensation incurred wholly and exclusively for business purposes, the Tribunal held that any incidental benefit to the parent entity from a motivated workforce does not negate the assessee's business purpose or s. 37(1) conditions. The ESOP expenditure was therefore treated as revenue expenditure and allowed as a deduction while computing income, resulting in relief to the assessee. Case-Laws Income Tax Mon, 30 Sep 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239041