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Documents citing Dcit (Tds)1(1), Mumbai vs Accenture Services P.Ltd, Mumbai on 9 November, 2016

Dcit 14(2)(1), Mumbai vs Kotak Mahindra Asset Management ... on 31 October, 2018

the aforementioned case, the Tribunal relying on its earlier decisions i.e. (i) DCIT Vs. Accentures Services Pvt. Ltd. [(2010) TIOL-409-ITAT- Mum] and (ii) Novo Nordisk India Pvt. Ltd. Vs. DCIT [ITA No. 1275/Bang/2011; dated 30.09.2013], had observed that the difference in the market price and the exercise price of the shares of the parent/holding company which were issued to the employees of the subsidiary company, having been paid by the latter, was thus allowable as an ESOP expense in its hands. We have perused the order of the Tribunal passed in the assesses own case for A.Y. 2004- 05, and finding ourselves as being in agreement with the view therein taken, thus respectfully follow the same. Before parting, we may herein observe that the Ld. D.R had not brought to our notice any such judgment or order wherein a contrary view had been taken.
Income Tax Appellate Tribunal - Mumbai Cites 25 - Cited by 3 - Full Document

Dcit 7(1)(1), Mumbai vs Goldman Sachs (India) Securities P.Tl, ... on 17 February, 2022

• As the Assessee is required to pay aforesaid sum to GSGI on account of the grant of the RSUs to its employees, such payment being an actual expenditure for the Assessee is considered as part of the compensation cost of the employees in the year in which it is incurred in accordance with the method of accounting followed 5.2.2 Therefore, the ESOP expenses should not be regarded as contingent or notional and it should be allowed as deduction u/s 37(1) of the IT. Act. The appellant had relied on the decision of DCIT v Accenture Services P Ltd [ITA No. 4540/M/08 order dated 23rd March 2010] and Novo Nordisk India Private Limited v DCIT -12(2) (ITA No.1275/Bang/2011) (Bang Trib).
Income Tax Appellate Tribunal - Mumbai Cites 28 - Cited by 12 - Full Document

Red Hat India P. Ltd, Mumbai vs Addl/Jt/Dy/Asstt/Cit/Ito, Nfac, , ... on 25 February, 2022

84. Since it is the case of the assessee that the Ld. DRP has failed to appreciate the additional evidence brought on record by the assessee and the AO has failed to examine the "recharge agreement" and "internal memorandum prior to the execution of recharge agreement" and has never sought "valuation report" or the "incentive plan", we are of the considered view that this issue is required to be remitted back to the AO to decide afresh after providing opportunity of being heard to the assessee, in the light of the case law relied upon by the assessee viz. the Mumbai Tribunal in case of DCIT v. Accenture Services Pvt. Ltd. (ITA Nos.
Income Tax Appellate Tribunal - Mumbai Cites 22 - Cited by 10 - Full Document

Acit Circle-6(2), New Delhi vs Cvent India Pvt. Ltd., Delhi on 24 February, 2023

A perusal of the assessment order shows that the AO has disallowed the expenditure u/s 37(1) of the Income Tax Act on two counts viz, expenditure had not crystallized and expenditure was not capital in nature. In regard to the former the appellant contended that the expenditure had been actually incurred by the appellant company and cross charges in this regard had been paid to the parent company. The appellant also filed a copy of Form 15CBS to authenticate payment so affected along with copy of bank statements of the appellant company. The AR also drew my attention to Note 32 of Audited financial Statements which reflects the details of cross charge. The ARs also placed reliance on the judgement of the Bangalore Tribunal in the case of Novo Nordisk India (P) Ltd, Mumbai Tribunal in the case of DCIT Vs Accenture Services (P) Ltd and ITAT Delhi in the case of Lemon Tree Hotels Ltd to strengthen his argument that such an expenditure is allowable under the aegis of Section 37(1) of the Income Tax Act. Regarding the latter the AR submitted that the expenditure was incurred to incentivize employees to continue working with the appellant company and is not in the nature of capital expenditure. The ARS of the appellant also produced a copy of the Job Offer letters to the employees and advance pricing agreement with CBDT.
Income Tax Appellate Tribunal - Delhi Cites 18 - Cited by 0 - Full Document

Asst. Commissioner Of Income-Tax ... vs Incred Holdings Limited (Formerly ... on 17 October, 2024

I.T.A. No. 4246/Mum/2024 I.T.A. No. 4248/Mum/2024 I.T.A. No. 4249/Mum/2024 I.T.A. No. 4250/Mum/2024 I.T.A. No. 4252/Mum/2024 I.T.A. No. 4254/Mum/2024 I.T.A. No. 4364/Mum/2024 I.T.A. No. 4365/Mum/2024 I.T.A. No. 4366/Mum/2024 I.T.A. No. 4373/Mum/2024 13 • DCIT vs. Accenture Services Pvt. Ltd. 4540 (Mum) of 2008 • Novo Nordisk (India) Pvt. Ltd. vs. DCIT( 2014) SOT 242 (Banglore ITAT) • Korn Ferry International Pvt. Ltd. vs. ACIT (OSD) ITA No. 7367/Mum/2014 • Biocon Ltd. vs. DCIT (2013) 35 taxmann.com 335
Income Tax Appellate Tribunal - Mumbai Cites 18 - Cited by 0 - Full Document

Asst. Commissioner Of Income-Tax ... vs Incred Holdings Limited (Formerly ... on 17 October, 2024

I.T.A. No. 4246/Mum/2024 I.T.A. No. 4248/Mum/2024 I.T.A. No. 4249/Mum/2024 I.T.A. No. 4250/Mum/2024 I.T.A. No. 4252/Mum/2024 I.T.A. No. 4254/Mum/2024 I.T.A. No. 4364/Mum/2024 I.T.A. No. 4365/Mum/2024 I.T.A. No. 4366/Mum/2024 I.T.A. No. 4373/Mum/2024 13 • DCIT vs. Accenture Services Pvt. Ltd. 4540 (Mum) of 2008 • Novo Nordisk (India) Pvt. Ltd. vs. DCIT( 2014) SOT 242 (Banglore ITAT) • Korn Ferry International Pvt. Ltd. vs. ACIT (OSD) ITA No. 7367/Mum/2014 • Biocon Ltd. vs. DCIT (2013) 35 taxmann.com 335
Income Tax Appellate Tribunal - Mumbai Cites 18 - Cited by 0 - Full Document

Incred Holdings Limited, Mumbai vs Assistant Commissioner Of Income Tax ... on 17 October, 2024

I.T.A. No. 4246/Mum/2024 I.T.A. No. 4248/Mum/2024 I.T.A. No. 4249/Mum/2024 I.T.A. No. 4250/Mum/2024 I.T.A. No. 4252/Mum/2024 I.T.A. No. 4254/Mum/2024 I.T.A. No. 4364/Mum/2024 I.T.A. No. 4365/Mum/2024 I.T.A. No. 4366/Mum/2024 I.T.A. No. 4373/Mum/2024 13 • DCIT vs. Accenture Services Pvt. Ltd. 4540 (Mum) of 2008 • Novo Nordisk (India) Pvt. Ltd. vs. DCIT( 2014) SOT 242 (Banglore ITAT) • Korn Ferry International Pvt. Ltd. vs. ACIT (OSD) ITA No. 7367/Mum/2014 • Biocon Ltd. vs. DCIT (2013) 35 taxmann.com 335
Income Tax Appellate Tribunal - Mumbai Cites 18 - Cited by 0 - Full Document

Incred Holdings Limited, Mumbai vs Assistant Commissioner Of Income Tax ... on 17 October, 2024

I.T.A. No. 4246/Mum/2024 I.T.A. No. 4248/Mum/2024 I.T.A. No. 4249/Mum/2024 I.T.A. No. 4250/Mum/2024 I.T.A. No. 4252/Mum/2024 I.T.A. No. 4254/Mum/2024 I.T.A. No. 4364/Mum/2024 I.T.A. No. 4365/Mum/2024 I.T.A. No. 4366/Mum/2024 I.T.A. No. 4373/Mum/2024 13 • DCIT vs. Accenture Services Pvt. Ltd. 4540 (Mum) of 2008 • Novo Nordisk (India) Pvt. Ltd. vs. DCIT( 2014) SOT 242 (Banglore ITAT) • Korn Ferry International Pvt. Ltd. vs. ACIT (OSD) ITA No. 7367/Mum/2014 • Biocon Ltd. vs. DCIT (2013) 35 taxmann.com 335
Income Tax Appellate Tribunal - Mumbai Cites 18 - Cited by 0 - Full Document
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