https://www.taxtmi.com/caselaws?id=774370 ITAT Ahmedabad set aside the PCIT's revision under s.263 and upheld the AO's assessment in favour of the assessee. The Tribunal held that donations to institutions approved under s.80G(5) - even if funded from CSR expenditure - were allowable under s.80G, as the statutory restriction in s.80G(2)(a) is limited to specified funds and Explanation 2 to s.37(1) cannot nullify Chapter VI-A deductions. The Tribunal also found no failure in the AO's examination of the GST input-credit write-off under s.37(1); differing conclusions by the Commissioner amounted to mere change of opinion, so the revision was quashed. en-us Fri, 04 Jul 2025 00:00:00 +0530 Thu, 25 Sep 2025 11:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774370 ITAT Ahmedabad set aside the PCIT's revision under s.263 and upheld the AO's assessment in favour of the assessee. The Tribunal held that donations to institutions approved under s.80G(5) - even if funded from CSR expenditure - were allowable under s.80G, as the statutory restriction in s.80G(2)(a) is limited to specified funds and Explanation 2 to s.37(1) cannot nullify Chapter VI-A deductions. The Tribunal also found no failure in the AO's examination of the GST input-credit write-off under s.37(1); differing conclusions by the Commissioner amounted to mere change of opinion, so the revision was quashed. Case-Laws Income Tax Fri, 04 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774370