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ITAT allowed the appeal and quashed the impugned revisionary order passed by the PCIT. The Tribunal held that a Co-ordinate Bench decision in the assessee's own case for an earlier assessment year squarely governed the present disputes - denial of Chapter-VIA deduction claimed u/s 80G and disallowance of ESOP expenditure claimed u/s 37(1) (and the assessee's suo moto disallowance of CSR expenditure) - and found no cogent material from Revenue to distinguish or controvert those findings. As the factual matrix was identical, the earlier appellate conclusions were applied mutatis mutandis, rendering the revisionary proceedings and resultant order unsustainable.
ITAT allowed the appeal and quashed the impugned revisionary order passed by the PCIT. The Tribunal held that a Co-ordinate Bench decision in the assessee's own case for an earlier assessment year squarely governed the present disputes - denial of Chapter-VIA deduction claimed u/s 80G and disallowance of ESOP expenditure claimed u/s 37(1) (and the assessee's suo moto disallowance of CSR expenditure) - and found no cogent material from Revenue to distinguish or controvert those findings. As the factual matrix was identical, the earlier appellate conclusions were applied mutatis mutandis, rendering the revisionary proceedings and resultant order unsustainable.
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