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    <title>2025 (4) TMI 328 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai allowed the appeal against PCIT&#039;s revision order under section 263. The PCIT had held that AO&#039;s allowance of contribution to Core SGF was erroneous as it constituted a contingent liability not deductible under section 37. However, ITAT found that AO had properly inquired into the matter during assessment proceedings. The Tribunal relied on its own precedent in assessee&#039;s case, holding that statutory contribution to Core SGF is allowable under section 37(1) as business expenditure for stock exchange operations. Since AO&#039;s view was plausible and supported by Tribunal precedent, PCIT&#039;s revision was unjustified.</description>
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      <link>https://www.taxtmi.com/caselaws?id=768414</link>
      <description>ITAT Mumbai allowed the appeal against PCIT&#039;s revision order under section 263. The PCIT had held that AO&#039;s allowance of contribution to Core SGF was erroneous as it constituted a contingent liability not deductible under section 37. However, ITAT found that AO had properly inquired into the matter during assessment proceedings. The Tribunal relied on its own precedent in assessee&#039;s case, holding that statutory contribution to Core SGF is allowable under section 37(1) as business expenditure for stock exchange operations. Since AO&#039;s view was plausible and supported by Tribunal precedent, PCIT&#039;s revision was unjustified.</description>
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