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IN THE HIGH COURT OF KARNATAKA AT BENGALURU
S.R. Krishna Kumar
Manjeet Singh Chawla, Son of Mr. Jawahar Singh Chawla – Appellant
Versus
Deputy Commissioner of TDS Ward-(1)(2) – Respondent
ORDER :
S.R. Krishna Kumar, J.
This petition takes an exception to the impugned order dated 02.08.2023 passed by the 1st respondent, whereby the request of the petitioner for issuance of ‘Nil Tax Deduction Certificate’ for Income Tax in favour of the petitioner for the financial year 2023-24 was rejected and for consequential directions to the respondents to issue the said ‘Nil Tax Deduction Certificate’ for Income Tax under Section 197 of the INCOME TAX ACT , 1961 (for short ‘the I.T. Act’)and for other reliefs.
2. Briefly stated the facts giving rise to the present petition are as under:
Petitioner is an Indian Citizen and a salaried employee of Flipkart Internet Private Limited (FIPL) which is an Indian Subsidiary of Flipkart Marketplace Private Limited (FMPL), a Company incorporated in Singapore which is further a wholly owned subsidiary of Flipkart Private Limited, Singapore (FPS). In addition to FMPL, FPS has many other subsidiaries including PhonePe which had a wholly owned subsidiary in India known as PhonePe India Private Limited.
2.1 In the year 2012, FPS introduced the Flipkart Stock Action Plan, 2012 (FSOP), pursuant to which the petitioner was granted 2232 stock options w
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