https://www.taxtmi.com/caselaws?id=781001 ITAT MUMBAI - AT held that the Principal Commissioner's invocation of section 263 was unsustainable and quashed the revision. The revisional power under s.263 is limited to patent errors causing prejudice to the Revenue and does not permit reappreciation of evidence; Explanation 2 applies only to absence of enquiry. The Principal Commissioner's finding that a Rs.58.02 crore receipt was reimbursement of ESOP cost was a factual misconception-records showed it was only TDS pass-through. On merits, ESOP discount is an allowable business expenditure under s.37(1). Assessee's appeal allowed. en-us Fri, 31 Oct 2025 00:00:00 +0530 Mon, 10 Nov 2025 08:56:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781001 ITAT MUMBAI - AT held that the Principal Commissioner's invocation of section 263 was unsustainable and quashed the revision. The revisional power under s.263 is limited to patent errors causing prejudice to the Revenue and does not permit reappreciation of evidence; Explanation 2 applies only to absence of enquiry. The Principal Commissioner's finding that a Rs.58.02 crore receipt was reimbursement of ESOP cost was a factual misconception-records showed it was only TDS pass-through. On merits, ESOP discount is an allowable business expenditure under s.37(1). Assessee's appeal allowed. Case-Laws Income Tax Fri, 31 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781001