2026 (4) TMI 120

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....ed CIT-A) dated 30th October, 2025 wherein appeal filed by the assessee on 24th April, 2025 against assessment order dated 26th March, 2025 passed under Section 143(3) of the Income Tax Act, 1961 (the Act) by the Deputy Commissioner of Income Tax Circle 3(1)(1) Bengaluru, was partly allowed. 2. The learned Assessing Officer aggrieved with the same has preferred this appeal raising following grounds of appeal: - i. On the facts and in law the learned CIT - A has erred in deleting the disallowance of ESOP expenditure amounting to Rs. 903,035,787/-, without properly appreciating that the said expenditure is notional in nature, does not involve any actual outflow of funds, and therefore does not qualify as an allowable expenditure u....

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.... business of development of computer software for export, Information Technology Services, Software Services, trading, leasing and financing of hardware and maintenance of computer equipments. The assessee filed Return of Income on 25thNovember 2022 at a total income of Rs 40,77,72,04,140. The Return of Income was picked up for scrutiny by issuing notice under Section 143(2) of the Act on 2ndJune 2023. The learned Assessing Officer passed the Assessment Order under Section 143(3) on 26thMarch 2025 wherein one of the disallowances was Employee's Stock Option Plan Expenditure of Rs. 90,30,35,787/-. This disallowance was made by the learned Assessing Officer because though assessee has stated so many judicial precedents, however similar issues....