Tax Revision Quashed: ESOP Expenditure Correctly Debited, Section 263 Misapplied by Principal Commissioner.

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....Revision u/s 263 by CIT - allowability of ESOP expenditure - No hesitation in holding that assessee had rightly debited the ESOP compensation cost of ₹ 32.55 Crores in the year of vesting as an expenditure - the ld. PCIT had invoked revisionary jurisdiction based on incorrect assumption of fact. Apart from this, we also hold that adequate enquiries were indeed made by the ld. AO in the course of assessment proceedings. - Hence, we have no hesitation in quashing the revision order passed by the ld. PCIT in this regard. Accordingly, the grounds raised by the assessee on account of ESOP expenditure are allowed - AT....