September 27, 2026
ITAT Bengaluru on Repurchase of Unexercised ESOPs: Capital Gains, Not Salary PerquisitesThe ITAT ruling on Pramod Kumar Jain case offers a carefully reasoned framework for taxing consideration received on repurchase of vested but unexercised ESOPs. Its central proposition, that a vested option and an exercised option are legally distinct, and that the vested option may itself constitute capital asset under section 2(14).
