(i) A stock option which is subject to a ‘lock-in’ is not a chargeable perquisite u/s 17(2) on the date of grant, vesting or exercise. The benfit is purely notional.

(ii) s. 17(2)(iiia) inserted w.e.f 1.4.2000 is not clarificatory;

(iii) Every “benefit” is not chargeable unless it is in the nature of ‘income’ or specifically made chargeable;

(iv) Estimation of TDS u/s 192 in the absence of clear provisions on
valuation of “perquisite” does not justify the department treating the employer as an assessee-in-default.