The Madras High Court and some tax authorities take a view and consider the compensation a taxable perquisite under the “Salaries” head if paid due to employment and not linked to transfer of capital asset.
When SARs are exercised and settled in cash, the payout is considered salary income taxed as a perquisite under section 17(2) of the Income Tax Act, and employers are required to deduct TDS under section 192.
If SARs are settled by allotment of shares and the employee subsequently sells those shares, the gain arising from the sale (difference between sale price and market value at exercise) would be taxed as capital gains—but the initial value received at exercise (market value minus grant price) was already taxed as a perquisite.