Topic

ESOP deduction

2 articlesLatest August 2026
Section 37 IT Act | ESOP Cross-Charges by Foreign Parent to Indian Subsidiary Allowable as Revenue Expenditure : ITAT Bangalore
Case Law Analysis
|Income Tax Appellate Tribunal

Section 37 IT Act | ESOP Cross-Charges by Foreign Parent to Indian Subsidiary Allowable as Revenue Expenditure : ITAT Bangalore

ITAT Bangalore rules that ESOP cross-charges from a foreign parent to its Indian subsidiary qualify as revenue expenditure under Section 37, overturning the disallowance of ₹721 crore. The decision clarifies that employee compensation costs, even when recharged, are deductible if incurred wholly for business purposes, impacting multinational tax structures.