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The ITAT held that the issue of allowing CSR expenses as a deduction under section 80G is highly debatable, with consistent precedents from coordinate benches supporting such claims. The Tribunal concluded that the Assessing Officer's original view on the matter constitutes a plausible interpretation. Consequently, the Principal Commissioner of Income Tax's revision under section 263, premised on a mere change of opinion, was held to be without jurisdiction. A difference of opinion alone does not render the assessment order erroneous or prejudicial to revenue. Therefore, the appeal filed by the assessee was allowed, and the revision order passed under section 263 was set aside.
The ITAT held that the issue of allowing CSR expenses as a deduction under section 80G is highly debatable, with consistent precedents from coordinate benches supporting such claims. The Tribunal concluded that the Assessing Officer's original view on the matter constitutes a plausible interpretation. Consequently, the Principal Commissioner of Income Tax's revision under section 263, premised on a mere change of opinion, was held to be without jurisdiction. A difference of opinion alone does not render the assessment order erroneous or prejudicial to revenue. Therefore, the appeal filed by the assessee was allowed, and the revision order passed under section 263 was set aside.
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