GREEN AGREVOLUTION PRIVATE LIMITED,INDIA vs. INCOME TAX OFFICER, PATNA

ITA 284/PAT/2026Status: DisposedITAT Patna20 July 2026AY 2022-2310 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that ESOP expenditure, representing employee compensation accrued over the vesting period, is an allowable business expense under Section 37(1) of the Income Tax Act. The disallowance by the lower authorities was deemed incorrect.

What were the facts?

The assessee, Green Agrevolution Private Limited, claimed ESOP expenditure of INR 19,51,19,001/-. The Assessing Officer disallowed this expenditure, considering it contingent and capital in nature. The CIT(A) upheld the disallowance.

What were the issues?

The primary issue was whether ESOP expenditure, treated as contingent by the revenue, is an allowable deduction as a business expense. The Tribunal also considered the applicability of accounting standards and judicial precedents.

Which sections of the Income-tax Act were involved?

Section 37(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PATNA “DB” BENCH

Before: SHRI LAXMI PRASAD SAHU & SHRI YOGESH KUAMR U.S.

For Appellant: Shri Akash Uppal, AR
For Respondent: Shri Bharat Garg, CIT, DR
Hearing: 29.06.2026Pronounced: 20.07.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER:

This Appeal is filed by the assessee against the order of the NFAC, Delhi [“the Ld. CIT(A)”, for short], dated 26.02.2026 with DIN & Order No. ITBA/NFAC/S/250/2025-26/1086577664(1) passed u/s 250 of the Income Tax Act, 1961 (“the Act”, for short) for the assessment year 2022-23 on following Grounds of Appeal:- Each of the ground and sub ground of appeals are independent and without prejudice to the other: -

1.

On the facts and circumstances of the case & in law, the order passed by learned Commissioner of Income Tax (Appeals) (Ld. CIT(A)], is unjust, arbitrary and contrary to the provisions of the Act, and bad

The order continues below.

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