ACIT, CIRCLE-7(1), DELHI, DELHI vs. FIS GLOBAL BUSINESS SOLUTIONS INDIA PRIVATE LIMITED, DELHI

ITA 5002/DEL/2025Status: DisposedITAT Delhi14 January 2026AY 2020-211 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that ESOP expenditure is allowable under Section 37(1) following previous decisions. It further held that CSR expenditure, even if disallowed under Section 37(1), is eligible for deduction under Section 80G as it fulfills the conditions for donation.

What were the facts?

The Revenue appealed against the CIT(A)'s order allowing ESOP expenditure as allowable under Section 37(1) and also allowing deduction under Section 80G for CSR expenses. The assessee had claimed ESOP expenses and donations made under CSR.

What were the issues?

Whether ESOP expenditure is allowable as a business expense and whether CSR expenditure qualifies for deduction under Section 80G.

Which sections of the Income-tax Act were involved?

Section 37(1),Section 80G

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Cases cited in this judgment(9)Show list

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Income Tax Appellate Tribunal, DELHI BENCH, ‘E’: NEW DELHI

Before: SHRI C.N. PRASAD & SHRI NAVEEN CHANDRA

For Appellant: Ms. Reema Grewal, CA
For Respondent: Ms. Ankush Kalra, Sr. DR, Ms. Reema Grewal, CA
Hearing: 18.11.2025Pronounced: 14.01.2026

Heard together (2 matters)

Co. No. 213/Del/2025
ITA No.5002/Del/2025

Read from the judgment's own cause title. This page is filed under one of them.

PER C.N. PRASAD, JM, This appeal is filed by the Revenue and cross objection filed by the Assessee against the order of the Ld.Commissioner of Income Tax (Appeals)/NFAC, Delhi [herein after referred as “CIT(A)”] for the dated 10.06.2025 for the A.Y. 2020-21. 2. The revenue in its appeal raised the following grounds :-

“1.1 The Assessing Officer, National e-Assessment Centre ('AO, NeAC') and CIT(A), NFAC fail

The order continues below.

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