Ramesh Kumar, is employed by ABC Ltd., an Indian Company, which is a wholly owned subsidiary (WOS) of Finch Inc., of USA, a foreign company. Employee Ownership Plan (ESOP) shares were issued by the foreign holding compan

Ramesh Kumar, is employed by ABC Ltd., an Indian Company, which is a wholly owned subsidiary (WOS) of Finch Inc., of USA, a foreign company. Employee Ownership Plan (ESOP) shares were issued by the foreign holding company to Ramesh Kumar at a pre-determined price of ₹90 per share. On the date of vesting of interest, the fair market value of foreign holding company's shares was ₹900 per share. The fair market value on the date of allotment of shares on 2nd June, 2018 was ₹1,170 per share. You are required to state : Can he claim deduction in respect of pre-determined price of ₹90 per share paid by him to the company while working out the value of perquisite subject to tax ?