https://www.taxtmi.com/caselaws?id=800975 Discount on shares issued under an employee stock option plan is deductible as revenue expenditure under Section 37(1) where it is incurred wholly and exclusively to secure and incentivise employee services for earning profits. The discount, being the difference borne between the share price and market value, constitutes a business outgo or loss rather than a short receipt of capital. Liability arises as a definite business liability when the options vest; subsequent exercise affects quantification rather than the character of the expenditure. The discount is therefore allowable as a revenue deduction. en-us Wed, 16 Sep 2026 00:00:00 +0530 Wed, 14 Oct 2026 06:17:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800975 Discount on shares issued under an employee stock option plan is deductible as revenue expenditure under Section 37(1) where it is incurred wholly and exclusively to secure and incentivise employee services for earning profits. The discount, being the difference borne between the share price and market value, constitutes a business outgo or loss rather than a short receipt of capital. Liability arises as a definite business liability when the options vest; subsequent exercise affects quantification rather than the character of the expenditure. The discount is therefore allowable as a revenue deduction. Case-Laws Income Tax Wed, 16 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800975