ITAT held that the Pr. CIT's revision under section 263,...

ITAT held that the Pr. CIT's revision under section 263, invoking Explanation 2 clause (a) to contend that CSR outlays mandated by the Companies Act, 2013 cannot form the source of donations eligible for deduction under section 80G, was unsustainable. The Tribunal found the issue settled by its coordinate benches that donations made from CSR-mandated funds may qualify for deduction under section 80G if all statutory conditions of section 80G are satisfied. Consequently, the initiation and sustaining of revisionary proceedings were based on a misconstruction of law; the order passed under section 263 was quashed and the assessee's grounds of appeal were allowed.

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