https://www.taxtmi.com/caselaws?id=774810 Revision under section 263 was unsustainable for the CSR-related section 80G claim because the assessee disclosed the material facts, the Assessing Officer considered the issue, and the view taken was a plausible one after inquiry. A revisional authority cannot substitute a different opinion where the original assessment reflects application of mind on the same material. Revision was sustainable for the ESOP expenditure because the assessment order showed no inquiry or verification on that claim; complete lack of inquiry attracts Explanation 2 to section 263 and renders the order erroneous and prejudicial to the Revenue. The revisional order was therefore upheld in part and set aside in part. en-us Tue, 17 Jun 2025 00:00:00 +0530 Tue, 15 Jul 2025 08:39:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774810 Revision under section 263 was unsustainable for the CSR-related section 80G claim because the assessee disclosed the material facts, the Assessing Officer considered the issue, and the view taken was a plausible one after inquiry. A revisional authority cannot substitute a different opinion where the original assessment reflects application of mind on the same material. Revision was sustainable for the ESOP expenditure because the assessment order showed no inquiry or verification on that claim; complete lack of inquiry attracts Explanation 2 to section 263 and renders the order erroneous and prejudicial to the Revenue. The revisional order was therefore upheld in part and set aside in part. Case-Laws Income Tax Tue, 17 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774810