Section 263 revision fails where the Assessing Officer adopts a plausible view on a debatable CSR deduction issue.

Revisionary jurisdiction under section 263 cannot be invoked where the Assessing Officer adopts one of two plausible views on a debatable issue. Here, the Tribunal held that the assessee's claim for deduction of CSR expenditure under section 80G was supported by a consistent line of coordinate Bench decisions, making the assessment order a plausible view. The Principal Commissioner's attempt to revise the order was treated as a mere change of opinion, which is insufficient to trigger section 263. Revision was therefore held unsustainable and the assessment order was restored in favour of the assessee.

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Issues: Whether revisionary jurisdiction under section 263 of the Income-tax Act, 1961 could be assumed where the Assessing Officer accepted the assessee's claim relating to CSR expenditure as deduction under section 80G.

Analysis: The issue was held to be highly debatable, and the Tribunal noted that coordinate Benches had taken a consistent view supporting the availability of deduction for CSR expenditure under section 80G. In such circumstances, the view taken by the Assessing Officer in the original assessment was treated as a plausible view. The revisionary view adopted by the Principal Commissioner was therefore regarded as a mere change of opinion, which could not justify invocation of section 263.

Conclusion: Revision under section 263 was not sustainable, and the assessment order was restored in favour of the assessee.

Ratio Decidendi: Section 263 cannot be invoked where the assessment order reflects one of two possible plausible views on a debatable issue and the revisional authority merely substitutes its own opinion.

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