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The ITAT upheld the AO's allowance of the CSR expenditure deduction under section 80G, finding the AO's assessment was a plausible and duly considered view, not erroneous or prejudicial, thus rejecting the revision under section 263 on this issue. The Tribunal recognized consistent precedents affirming CSR expenses' eligibility for deduction subject to compliance with other section 80G requirements. Conversely, regarding the ESOP matter, the Tribunal concurred with the PCIT that the AO failed to make any inquiry or verification, rendering the assessment order erroneous and prejudicial under Explanation 2 to section 263. The absence of any inquiry justified revisional jurisdiction to set aside the assessment for de novo consideration, ensuring adherence to natural justice. Consequently, the revision order was confirmed against the assessee on the ESOP issue but disallowed on the CSR deduction claim.
The ITAT upheld the AO's allowance of the CSR expenditure deduction under section 80G, finding the AO's assessment was a plausible and duly considered view, not erroneous or prejudicial, thus rejecting the revision under section 263 on this issue. The Tribunal recognized consistent precedents affirming CSR expenses' eligibility for deduction subject to compliance with other section 80G requirements. Conversely, regarding the ESOP matter, the Tribunal concurred with the PCIT that the AO failed to make any inquiry or verification, rendering the assessment order erroneous and prejudicial under Explanation 2 to section 263. The absence of any inquiry justified revisional jurisdiction to set aside the assessment for de novo consideration, ensuring adherence to natural justice. Consequently, the revision order was confirmed against the assessee on the ESOP issue but disallowed on the CSR deduction claim.
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