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Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
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The ITAT held that the assessment order was neither erroneous nor prejudicial to the revenue under section 263, as the AO had duly examined the claim of deduction under Chapter VI-A and adopted a plausible view allowing the entire donation made up to 30.06.2020. The revisionary power under section 263 requires satisfaction of both error and prejudice, which was not established. Regarding CSR expenditure under section 135 of the Companies Act, the tribunal noted that this issue is pending before the jurisdictional High Court and that coordinate benches have favored the assessee's claim of deduction under section 80G, a view the AO rightly followed. Consequently, the PCIT's revision order was set aside, and the appeal filed by the assessee was allowed.
The ITAT held that the assessment order was neither erroneous nor prejudicial to the revenue under section 263, as the AO had duly examined the claim of deduction under Chapter VI-A and adopted a plausible view allowing the entire donation made up to 30.06.2020. The revisionary power under section 263 requires satisfaction of both error and prejudice, which was not established. Regarding CSR expenditure under section 135 of the Companies Act, the tribunal noted that this issue is pending before the jurisdictional High Court and that coordinate benches have favored the assessee's claim of deduction under section 80G, a view the AO rightly followed. Consequently, the PCIT's revision order was set aside, and the appeal filed by the assessee was allowed.
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