https://www.taxtmi.com/highlights?id=94015 ITAT allowed the appeal and set aside the Principal Commissioner's revisional order under s.263. The Tribunal held that s.263 is confined to correcting patent errors causing prejudice to the Revenue and does not permit reappreciation of evidence or substitution of the AO's view; Explanation 2 applies only where enquiry or verification is absent. The Principal Commissioner's premise that the taxpayer recovered ESOP costs was a factual misconception: ledger, financials and TDS reconciliation demonstrated only statutory TDS pass-through, not reimbursement, negating any prejudice to the Revenue. On merits the ESOP discount was held deductible under s.37(1) as employee remuneration incurred wholly and exclusively for business, making the AO's acceptance a tenable view. en-us Mon, 10 Nov 2025 08:56:06 +0530 Mon, 10 Nov 2025 08:56:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=94015 ITAT allowed the appeal and set aside the Principal Commissioner's revisional order under s.263. The Tribunal held that s.263 is confined to correcting patent errors causing prejudice to the Revenue and does not permit reappreciation of evidence or substitution of the AO's view; Explanation 2 applies only where enquiry or verification is absent. The Principal Commissioner's premise that the taxpayer recovered ESOP costs was a factual misconception: ledger, financials and TDS reconciliation demonstrated only statutory TDS pass-through, not reimbursement, negating any prejudice to the Revenue. On merits the ESOP discount was held deductible under s.37(1) as employee remuneration incurred wholly and exclusively for business, making the AO's acceptance a tenable view. Highlights Income Tax Mon, 10 Nov 2025 08:56:06 +0530 https://www.taxtmi.com/highlights?id=94015