Description
In Ravi Kumar Sinha v. CIT (2024), the Delhi High Court held that shares allotted under ESPS with lock-in restrictions have no immediate realizable value, and thus no taxable perquisite arises under Section 17(2). The ruling reaffirms that notional gains cannot be taxed in absence of enforceable, liquid benefits.
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Substance Check for PE Determination
Taxability of Employee Stock Purchase | Scheme (‘ESPS’) in the hands of Employees
Stay of demand must consider merits and hardship, not rigid 20% pre-deposit
VCH - Global Transfer Pricing | Tax | Accounting | V-CFO
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