https://www.taxtmi.com/caselaws?id=774969 The ITAT Mumbai quashed the revision order under section 263 initiated by the Principal Commissioner of Income Tax. The case involved a deduction claim under section 80G where the assessee claimed 50% deduction on donations made. The AO had sought explanations through notices under section 142(1) regarding various issues including the section 80G deduction, and the assessee provided detailed replies with supporting documents. Since the AO did not make adverse references in the assessment order, the ITAT held that the AO impliedly accepted the assessee's explanation. The tribunal relied on precedents including Gabriel India Ltd., Vistex Asia Pacific, and Axis Securities Limited, which consistently allowed 50% deduction under section 80G on CSR expenses. The ITAT concluded that the twin conditions for revision under section 263 were not fulfilled as the AO's acceptance of the claim was legally sustainable, ruling in favor of the assessee. en-us Fri, 27 Jun 2025 00:00:00 +0530 Thu, 17 Jul 2025 08:19:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774969 The ITAT Mumbai quashed the revision order under section 263 initiated by the Principal Commissioner of Income Tax. The case involved a deduction claim under section 80G where the assessee claimed 50% deduction on donations made. The AO had sought explanations through notices under section 142(1) regarding various issues including the section 80G deduction, and the assessee provided detailed replies with supporting documents. Since the AO did not make adverse references in the assessment order, the ITAT held that the AO impliedly accepted the assessee's explanation. The tribunal relied on precedents including Gabriel India Ltd., Vistex Asia Pacific, and Axis Securities Limited, which consistently allowed 50% deduction under section 80G on CSR expenses. The ITAT concluded that the twin conditions for revision under section 263 were not fulfilled as the AO's acceptance of the claim was legally sustainable, ruling in favor of the assessee. Case-Laws Income Tax Fri, 27 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774969