Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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