https://www.taxtmi.com/caselaws?id=802164 Revision of an assessment under Section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Where employee stock option expenditure is allowed after the Assessing Officer obtains explanations and supporting material, the absence of detailed discussion in the assessment order does not itself establish a lack of enquiry. Revision cannot rest merely on substituting a different view for a legally permissible view adopted after enquiry. Allowance of the expenditure under Section 37(1) is a permissible view supported by High Court authority; admission of a special leave petition without a stay or reversal does not displace that authority. en-us Thu, 24 Sep 2026 00:00:00 +0530 Mon, 02 Nov 2026 08:31:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802164 Revision of an assessment under Section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. Where employee stock option expenditure is allowed after the Assessing Officer obtains explanations and supporting material, the absence of detailed discussion in the assessment order does not itself establish a lack of enquiry. Revision cannot rest merely on substituting a different view for a legally permissible view adopted after enquiry. Allowance of the expenditure under Section 37(1) is a permissible view supported by High Court authority; admission of a special leave petition without a stay or reversal does not displace that authority. Case-Laws Income Tax Thu, 24 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802164