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    <title>2025 (2) TMI 1735 - ITAT DELHI</title>
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    <description>Employee stock option and restricted stock unit costs were treated as deductible business expenditure where the record showed actual cost allocation, employee-wise recovery by the overseas group company, and a direct employee-benefit nexus. IT support service charges paid to the overseas group company were also allowed because invoices, TDS details, allocation basis, and evidence of receipt established business purpose and commercial expediency. Testers and promotional expenditure was likewise held to be revenue expenditure, as it supported market presence, product promotion, and routine business operations. The substantive expenditure claims were therefore allowed, while the sales return rectification issue was left for separate proceedings, resulting in partial relief to the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=467909</link>
      <description>Employee stock option and restricted stock unit costs were treated as deductible business expenditure where the record showed actual cost allocation, employee-wise recovery by the overseas group company, and a direct employee-benefit nexus. IT support service charges paid to the overseas group company were also allowed because invoices, TDS details, allocation basis, and evidence of receipt established business purpose and commercial expediency. Testers and promotional expenditure was likewise held to be revenue expenditure, as it supported market presence, product promotion, and routine business operations. The substantive expenditure claims were therefore allowed, while the sales return rectification issue was left for separate proceedings, resulting in partial relief to the assessee.</description>
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