2018 (4) TMI 1858

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....isallowance on account of the difference between purchase price of the Stock Appreciation Rights (SAR) and the sale price of such shares at the time of the exercise by the employees, which was disallowed in the hands of the Revenue. The Scheme is analogous to the Employee stock appreciation rights scheme 2007 and is covered in the favour of the assesse by the ruling of this Court in the case of 'C....

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....e Act. Here the Revenue authorities, including the CIT (A), disallowed certain amounts contending that the failure to deduct tax at source from the amount paid to other entities authorized the disallowance. The ITAT noted that the amounts were paid by way of reimbursement and that there was no finding to the effect that the reimbursement contained any income element. On account of these findings t....