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2022 (9) TMI 1036 - ITAT DELHIDeduction for ESOP Expenditure - ESOP expenditure allowable revenue expenditure u/s 37 or not? - HELD THAT:- The submission of the assessee has considerable cogency. DRs objections that the payment was made during the next year, assessee has contended that two year amount including the present year, where billed by ITC Ltd. and though the payment was made in the next year, Rs.2.58 Crores thereof belonged to present assessment year. In our considered opinion, both the submission has considerable cogency. Several factual aspects have been mentioned by assessee which need verification at the level of the AO. Hence, the factual aspects that there were employees deputed by ITC Ltd. for working for assessee and that expenditure was actually paid during the next year but it related to current year and financials of current year were duly recasted, are subject to examination by the AO and hence we direct the AO factually verify this issue and thereafter pass order as per our observations hereinabove. Appeal of the assessee is partly allowed for statistical purposes.
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