TMI Blog2014 (7) TMI 1175X X X X Extracts X X X X X X X X Extracts X X X X ..... ing ₹ 8,66,634/-, which was computed as gain on account of difference in market price of the shares in USA allotted to the assessee under the stock option. The actual difference between the market price and the shares allotted upon conversion in Indian rupees was ₹ 32,09,756/-. The assessee had taken to proportionate amount and declared ₹ 8,66,634/- as taxable in India, keeping i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , Jr. Standing Counsel. For the Respondent : Mr. Nageswar Rao and Mr. Sandeep S. Karhail, Advocates. O R D E R Two issues have been raised in the present appeal by the Revenue impugning order dated 24th May, 2013 passed by the Income Tax Appellate Tribunal (Tribunal). The first issue pertains to hypothetical tax and is covered by decision of this Court in ITA No. 1308/2008 titled ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... condition that he continued to remain in employment of the said company, i.e., from 9th January, 2004 till at least 8th January, 2007. On 1st April, 2006, the respondent-assessee was sent on deputation to the Indian Liaison Office of Technologies International Operation, USA and during the assessment year in question, i.e., 2007-08, was a resident and not an ordinary resident in India. The respon ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n India with reference to the dates 9th January, 2004 to 1st February, 2007. Thus, proportionately on the basis of the period spent in India, the employee stock option was brought to tax and taxed in India. The assessees in question, as noticed above, was an employee of a company registered and listed in USA. The option which was given to the assessee was pursuant to the respondent-assessee workin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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