R.S. Syal, Accountant Member. - This appeal by the assessee arises out of the order passed by the Commissioner of Income-tax (Appeals) on 5-1-2004 in relation to the assessment year 2001-02.

2. The only grievance raised through different grounds is against the direction of the learned CIT(A) of bringing to tax a sum of Rs. 32,75,716 under the head ‘Salaries’ in respect of stock option exercised by the assessee.

3. Briefly stated the facts of the case are that the assessee is employed at the Indian Branch Headquarters of American Express Bank Limited (hereinafter referred to as "AEBL") in the position of Senior Director. AEBL is a wholly owned subsidiary of the American Express International Banking Corporation, New York, which in turn is a wholly owned subsidiary of American Express Company, New York (hereinafter called ‘Amexco’). The assessee showed total income in the revised return at Rs. 66,65,177. The reason for revising the return was that he had not shown the capital gain of Rs. 2,35,310 in the original return, which resulted from sale of 385 shares of Amexco. The Assessing Officer observed that the assessee had not offered Rs. 32,75,716 for taxation, which represented sa