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The ITAT allowed the assessee's appeal against revision under section 263, holding that the PCIT exceeded jurisdictional authority. The Tribunal found that the deduction under section 80G for CSR expenditure claimed as donation was a debatable issue not warranting revisionary intervention. The PCIT failed to conduct proper inquiry or provide cogent reasons establishing that the assessment order was erroneous and prejudicial to revenue interests. Instead, the PCIT improperly set aside the order with directions for revision. The ITAT emphasized that Explanation 2 to section 263 does not confer unlimited power to revise orders where the AO has already properly examined issues and taken a plausible view. The impugned order was declared void ab initio.
The ITAT allowed the assessee's appeal against revision under section 263, holding that the PCIT exceeded jurisdictional authority. The Tribunal found that the deduction under section 80G for CSR expenditure claimed as donation was a debatable issue not warranting revisionary intervention. The PCIT failed to conduct proper inquiry or provide cogent reasons establishing that the assessment order was erroneous and prejudicial to revenue interests. Instead, the PCIT improperly set aside the order with directions for revision. The ITAT emphasized that Explanation 2 to section 263 does not confer unlimited power to revise orders where the AO has already properly examined issues and taken a plausible view. The impugned order was declared void ab initio.
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