https://www.taxtmi.com/caselaws?id=215197 HC held for the assessee: revision under s.263 is impermissible absent proof the order was erroneous and prejudicial to Revenue; receipts from exchange fluctuations on funds raised by issue of shares (including foreign currency) are capital receipts and do not become revenue simply because part of the share capital is used as working capital; Commissioner's unexplained change of view was invalid. Expenditure on issue of shares under ESOPs, incurred per regulatory direction, was allowable as staff welfare. Decision in favor of the assessee. en-us Tue, 19 Jun 2012 00:00:00 +0530 Sat, 20 Sep 2025 10:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=215197 HC held for the assessee: revision under s.263 is impermissible absent proof the order was erroneous and prejudicial to Revenue; receipts from exchange fluctuations on funds raised by issue of shares (including foreign currency) are capital receipts and do not become revenue simply because part of the share capital is used as working capital; Commissioner's unexplained change of view was invalid. Expenditure on issue of shares under ESOPs, incurred per regulatory direction, was allowable as staff welfare. Decision in favor of the assessee. Case-Laws Income Tax Tue, 19 Jun 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=215197