https://www.taxtmi.com/caselaws?id=790459 ITAT Mumbai noted that a bona fide fresh claim for employee stock option expense can be raised at the appellate stage where the relevant facts are on record and the claim is needed to compute correct taxable income; the restriction on the Assessing Officer does not limit appellate jurisdiction, and section 119(2)(b) does not bar such consideration. The foreign tax credit claim for taxes paid in Japan was also remitted for factual verification and treaty-based examination. The Revenue's objection to the employee compensation cost claim was rejected by following the assessee's own earlier year decision on identical facts. en-us Mon, 30 Mar 2026 00:00:00 +0530 Sat, 25 Apr 2026 08:51:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790459 ITAT Mumbai noted that a bona fide fresh claim for employee stock option expense can be raised at the appellate stage where the relevant facts are on record and the claim is needed to compute correct taxable income; the restriction on the Assessing Officer does not limit appellate jurisdiction, and section 119(2)(b) does not bar such consideration. The foreign tax credit claim for taxes paid in Japan was also remitted for factual verification and treaty-based examination. The Revenue's objection to the employee compensation cost claim was rejected by following the assessee's own earlier year decision on identical facts. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790459