Arm’s Length Price of Employee Stock Option Plan cannot be taken as NIL

Booking.Com India Support & Marketing Services Private Limited Vs DCIT (ITAT Mumbai) ITAT Mumbai held that Arm’s Length Price (ALP) of Employee Stock Option Plan (ESOP) cannot be taken as NIL. Accordingly, matter set aside with direction to re-compute ALP and transfer pricing adjustment. Facts- The Assessee filed return of income for the assessment year 2018-19. The case of the Appellant was selected for scrutiny and notice u/s. 143(2) of the Act. During the assessment proceedings AO noted that the Appellant had entered into international transactions with its Associated Enterprises (AEs...