https://www.taxtmi.com/caselaws?id=462610 ITAT Mumbai allowed assessee's appeal against PCIT's revision order u/s 263. PCIT had challenged AO's allowance of deduction u/s 80G for CSR expenditure, arguing that expenses disallowed u/s 37(1) cannot qualify for deduction u/s 80G. ITAT held that AO had conducted proper enquiry during reassessment and taken a plausible view. The tribunal ruled that sections 37(1) and 80G operate independently - section 37(1) governs business income computation while section 80G allows deduction from gross total income. Since assessee had properly disallowed CSR expenses under section 37(1) and met section 80G requirements with valid certificates, the deduction was sustainable. PCIT's revision order was reversed as AO's decision was neither erroneous nor prejudicial to revenue interests. en-us Tue, 03 Sep 2024 00:00:00 +0530 Thu, 03 Jul 2025 20:45:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462610 ITAT Mumbai allowed assessee's appeal against PCIT's revision order u/s 263. PCIT had challenged AO's allowance of deduction u/s 80G for CSR expenditure, arguing that expenses disallowed u/s 37(1) cannot qualify for deduction u/s 80G. ITAT held that AO had conducted proper enquiry during reassessment and taken a plausible view. The tribunal ruled that sections 37(1) and 80G operate independently - section 37(1) governs business income computation while section 80G allows deduction from gross total income. Since assessee had properly disallowed CSR expenses under section 37(1) and met section 80G requirements with valid certificates, the deduction was sustainable. PCIT's revision order was reversed as AO's decision was neither erroneous nor prejudicial to revenue interests. Case-Laws Income Tax Tue, 03 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462610