https://www.taxtmi.com/caselaws?id=783421 The ITAT Mumbai upheld the order of the CIT(A) allowing deduction of expenditure incurred under the ESOP scheme as revenue expenditure u/s 37(1). It noted that in the assessee's own cases for earlier assessment years, similar ESOP expenditure had been consistently held to be revenue in nature, and no change in facts or law had been demonstrated by the Revenue. Relying on this consistent view and tribunal precedent on ESOP-related discounts, the ITAT found the AO's disallowance unjustified and dismissed the Revenue's appeal in entirety. en-us Thu, 27 Nov 2025 00:00:00 +0530 Fri, 12 Dec 2025 11:40:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783421 The ITAT Mumbai upheld the order of the CIT(A) allowing deduction of expenditure incurred under the ESOP scheme as revenue expenditure u/s 37(1). It noted that in the assessee's own cases for earlier assessment years, similar ESOP expenditure had been consistently held to be revenue in nature, and no change in facts or law had been demonstrated by the Revenue. Relying on this consistent view and tribunal precedent on ESOP-related discounts, the ITAT found the AO's disallowance unjustified and dismissed the Revenue's appeal in entirety. Case-Laws Income Tax Thu, 27 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783421