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The ITAT quashed the revisionary order under section 263, upholding the assessment order under section 143(3) as neither erroneous nor prejudicial to Revenue. The PCIT failed to demonstrate any material difference in facts or law for AY 2020-21 compared to AY 2018-19 regarding foreign tax credit under section 90 for income from the Philippines branch. The AO's acceptance of reconciliation and evidence was sufficient application of mind. Additionally, the deduction under section 80G for donations qualifying under statutory criteria was rightly allowed despite CSR obligations, as section 37(1) Explanation 2 does not negate section 80G claims. Revisionary interference was thus unsustainable, and the appeal was allowed.
The ITAT quashed the revisionary order under section 263, upholding the assessment order under section 143(3) as neither erroneous nor prejudicial to Revenue. The PCIT failed to demonstrate any material difference in facts or law for AY 2020-21 compared to AY 2018-19 regarding foreign tax credit under section 90 for income from the Philippines branch. The AO's acceptance of reconciliation and evidence was sufficient application of mind. Additionally, the deduction under section 80G for donations qualifying under statutory criteria was rightly allowed despite CSR obligations, as section 37(1) Explanation 2 does not negate section 80G claims. Revisionary interference was thus unsustainable, and the appeal was allowed.
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