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    <title>2025 (8) TMI 374 - ITAT AHMEDABAD</title>
    <link>https://www.taxtmi.com/caselaws?id=776187</link>
    <description>ITAT Ahmedabad held that revision under s. 263 was unjustified as the AO&#039;s order u/s 143(3) was neither erroneous nor prejudicial to Revenue. The expected credit loss was not claimed as a deduction, negating any disallowance. Both s. 80G deduction for donation and ICDS adjustments were duly disclosed and considered by the AO without adverse findings. The Tribunal affirmed that CSR expenditure can qualify for deduction u/s 80G if conditions are met, relying on precedents. The AO&#039;s view was plausible and not liable to be substituted by PCIT merely for a differing opinion. Explanation 2 to s. 37(1) applies only to business income, not Chapter VIA deductions. Consequently, the revision order was quashed and the assessee&#039;s appeal allowed.</description>
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    <pubDate>Mon, 28 Jul 2025 00:00:00 +0530</pubDate>
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      <title>2025 (8) TMI 374 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=776187</link>
      <description>ITAT Ahmedabad held that revision under s. 263 was unjustified as the AO&#039;s order u/s 143(3) was neither erroneous nor prejudicial to Revenue. The expected credit loss was not claimed as a deduction, negating any disallowance. Both s. 80G deduction for donation and ICDS adjustments were duly disclosed and considered by the AO without adverse findings. The Tribunal affirmed that CSR expenditure can qualify for deduction u/s 80G if conditions are met, relying on precedents. The AO&#039;s view was plausible and not liable to be substituted by PCIT merely for a differing opinion. Explanation 2 to s. 37(1) applies only to business income, not Chapter VIA deductions. Consequently, the revision order was quashed and the assessee&#039;s appeal allowed.</description>
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      <pubDate>Mon, 28 Jul 2025 00:00:00 +0530</pubDate>
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