ACIT CEN CIR 13, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI
What did the Tribunal hold?
The Tribunal held that the discount on ESOPs represents an ascertained liability and is an allowable expenditure under Section 37(1) of the Income Tax Act. The revenue's appeals on this issue were dismissed.
What were the facts?
The assessee, engaged in pharmaceutical manufacturing and sales, filed returns for multiple assessment years. The appeals involved issues related to transfer pricing adjustments, deductions under Sections 80IB and 80IC, and the allowability of Employees' Stock Option Scheme (ESOP) expenses.
What were the issues?
The key issues were the correctness of transfer pricing adjustments, eligibility of certain income for deductions under Sections 80IB and 80IC, and the deductibility of ESOP expenses as a business expenditure.
Which sections of the Income-tax Act were involved?
Section 92CA,Section 80IB,Section 80IC,Section 37(1),Section 43(1),Section 32(1)(iia),Section 17(2)(iiia)
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Cases cited in this judgment(9)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- Radhasoami Satsang v. CIT1,695 citing193 ITR 321 · 1992 · SC
- Biocon Ltd. v. DCIT322 citing35 Taxmann.com 335 · 2013 · ITAT
- CIT v. Biocon Ltd.242 citing121 Taxmann.com 351 · 2020 · HC
- CIT v. PVP Ventures Ltd.143 citing23 Taxmann.com 286 · 2012 · HC
- CIT v. Sadhu Forging Ltd.73 citing336 ITR 444 · 2011 · HC · Read judgment
- CIT v. Shri T.P. Textiles (P.) Ltd.73 citing394 ITR 483 · 2017 · HC
- Dy. CIT v. Harjivandas Juthabhai Zaveri44 citing258 ITR 785 · 2002 · HC
- 133 Taxmann.com 14910 citing133 Taxmann.com 149 · 2021 · HC
- 176 Taxmann 28510 citing176 Taxmann 285
Income Tax Appellate Tribunal, “K” BENCH, MUMBAI
Before: SHRI PRASHANT MAHARISHI, AM & SHRI PAVAN KUMAR GADALE, JM
Heard together (5 matters)
Read from the judgment's own cause title. This page is filed under one of them.
PER PRASHANT MAHARISHI, AM:
This is the bunch of 10 appeals pertaining to M/s IPCA Laboratories Limited (the appellant/ assessee) for A.Ys. 2005- 06 to 2010-11 filed by the as
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