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    <title>2025 (8) TMI 379 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai reversed the disallowance of expenses paid to the parent company under ESOP and ISOP schemes, holding that these costs were incurred in the relevant year and constituted allowable revenue expenditure under section 37(1). The tribunal found that the appellant merely reimbursed actual costs related to its employees, supported by invoices, remittance documents, and TDS deductions. The expenditure was not capital in nature since no shares were issued by the appellant, nor did it receive any capital benefit. Reliance was placed on precedent from the Karnataka HC and SC emphasizing commercial expediency in allowing expenses aimed at retaining a competent workforce. The ITAT ruled in favor of the assessee, affirming the deductibility of the ESOP and ISOP expenses.</description>
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      <link>https://www.taxtmi.com/caselaws?id=776192</link>
      <description>The ITAT Mumbai reversed the disallowance of expenses paid to the parent company under ESOP and ISOP schemes, holding that these costs were incurred in the relevant year and constituted allowable revenue expenditure under section 37(1). The tribunal found that the appellant merely reimbursed actual costs related to its employees, supported by invoices, remittance documents, and TDS deductions. The expenditure was not capital in nature since no shares were issued by the appellant, nor did it receive any capital benefit. Reliance was placed on precedent from the Karnataka HC and SC emphasizing commercial expediency in allowing expenses aimed at retaining a competent workforce. The ITAT ruled in favor of the assessee, affirming the deductibility of the ESOP and ISOP expenses.</description>
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