In Brief
The Supreme Court dismissed an appeal by the Revenue against a High Court decision involving the taxation of Stock Appreciation Rights (SARs) received by the Chairman of Procter & Gamble India. The issue was whether Rs 6.80 crore received on SAR redemption in 1997 should be taxed as salary, perquisite, capital gains, or business income. The Court held that without an express statutory provision making such amounts taxable, they cannot be taxed. The amendment introducing specific SAR taxation (Section 17(2)(iiia)) came into effect only from 01.04.2000 and had no retrospective application, so it could not apply to the 1997 transaction.
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