https://www.taxtmi.com/caselaws?id=775160 The ITAT Mumbai held that the PCIT's order u/s 263 challenging the AO's allowance of deduction u/s 80G for CSR expenditure was invalid. The Tribunal found that the AO had conducted requisite enquiries and applied his mind to the issue, with the assessment order not being erroneous or prejudicial to revenue interests. The Tribunal noted divergent judicial views on allowing s 80G deduction for CSR donations, with Delhi Bench disallowing while Bangalore Benches permitting such claims. Relying on SC precedent in Max India Ltd., the Tribunal held that where two reasonable views exist and the AO adopted one supported by judicial pronouncements, the Commissioner cannot substitute his opinion merely due to preferring different interpretation. The PCIT's revisionary order was set aside and assessee's appeal was allowed. en-us Thu, 17 Jul 2025 00:00:00 +0530 Fri, 18 Jul 2025 12:53:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775160 The ITAT Mumbai held that the PCIT's order u/s 263 challenging the AO's allowance of deduction u/s 80G for CSR expenditure was invalid. The Tribunal found that the AO had conducted requisite enquiries and applied his mind to the issue, with the assessment order not being erroneous or prejudicial to revenue interests. The Tribunal noted divergent judicial views on allowing s 80G deduction for CSR donations, with Delhi Bench disallowing while Bangalore Benches permitting such claims. Relying on SC precedent in Max India Ltd., the Tribunal held that where two reasonable views exist and the AO adopted one supported by judicial pronouncements, the Commissioner cannot substitute his opinion merely due to preferring different interpretation. The PCIT's revisionary order was set aside and assessee's appeal was allowed. Case-Laws Income Tax Thu, 17 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775160