DCIT, MUMBAI vs. NOVARTIS HEALTHCARE PRIVATE LIMITED , MUMBAI
In the result, appeal by Revenue is dismissed and C
ITA 7386/MUM/2025[2021-22]Status: DisposedITAT Mumbai08 Jan 2026AY 2021-22
Bench: Shri Pawan Singh & Shri Arun Khodpia(Physical Hearing) Dcit Novartis Healthcare Private Limited, Room No.320, 3Rd Floor, Mtnl Te Vs 7Th Floor Inspire Bkc, G Block, Bkc Building, Pedder Road, Cumballa Main Road, Mumbai Hill, Mumbai [Pan:Aaacn5094N] Appellant / Assessee Respondent / Revenue
Section 194HSection 254(1)
employee exercises the option because employee had to fulfill certain conditions in subsequent years. The appellant company contends that this perquisite value under section 17(2)(vi) of the Act was taxable in A.Y. 2023-24 only.
8a. Per contra, Ld. DR argues that the appellant company has quantified ... liability on company arises only when the benefit is exercised and actually availed, but not at the stage of mere grant.
b) Section 17(2) (vi) of the Act and the Explanation says that on the date of transfer or allotment, the difference between FMV of option on the date