Deepak R. Shah, Accountant Member. - This appeal by the revenue is directed against the order of the learned Commissioner of Income-tax (Appeals)-XXI, New Delhi, dated 24-1-2003.

2. The revenue has raised following grounds before us :—

"1. On the facts and in the circumstances of the case, the ld. CIT(A) has erred in deleting the addition of Rs. 18,32,50,000 without appreciating the fact that the addition has been made correctly on account of perquisite in the hands of the assessee.

2. The ld. CIT(A) has erred in holding that the perquisite on account of stock option arose to the assessee on 1-2-1999 falling in assessment year 1999-2000 i.e., the date of offer and not on 30-4-1999 falling in assessment year 2000-01 when the assessee actually exercised the option.

3. The CIT(A) has erred in holding that the option was exercised on 15-4-1999 but the perquisite value would not be taxable in assessment year 2000-01 as in the return filed by the assessee for the assessment year 1999-2000 the income on transaction had been offered for tax."

3. The assessee herein is an individual. At the relevant time he was working as managing director of M/s. Zee Telefilms Ltd. During the year the asse