https://www.taxtmi.com/caselaws?id=785501 ESOP-related payments invoiced and remitted to the ultimate holding company may qualify as deductible business expenditure under section 37(1) where actual cash outflow is established. The Tribunal treated the payments as not merely notional, considered the transfer-pricing treatment of the international transactions, and applied binding jurisdictional High Court precedent supporting ESOP expense deductibility. Pendency of the Department's SLP before the Supreme Court did not displace the applicable High Court ruling. The deletion of the ESOP expense addition was therefore upheld. en-us Wed, 21 Jan 2026 00:00:00 +0530 Sat, 24 Jan 2026 08:39:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785501 ESOP-related payments invoiced and remitted to the ultimate holding company may qualify as deductible business expenditure under section 37(1) where actual cash outflow is established. The Tribunal treated the payments as not merely notional, considered the transfer-pricing treatment of the international transactions, and applied binding jurisdictional High Court precedent supporting ESOP expense deductibility. Pendency of the Department's SLP before the Supreme Court did not displace the applicable High Court ruling. The deletion of the ESOP expense addition was therefore upheld. Case-Laws Income Tax Wed, 21 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785501