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    <title>2025 (9) TMI 714 - ITAT MUMBAI</title>
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    <description>Revision under section 263 was considered in relation to an assessee&#039;s claim for deduction under section 80G on CSR expenditure. The Tribunal noted that the allowability of such deduction was a highly debatable issue and had been supported by consistent Tribunal decisions, so it could not be treated as an erroneous and prejudicial assessment for revisional purposes. The absence of a specific enquiry by the Assessing Officer did not justify revision where the claim was legally tenable and further verification would serve no useful purpose. On that basis, the revisional jurisdiction under section 263 was held unsustainable and the revisionary order was set aside.</description>
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      <title>2025 (9) TMI 714 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=778225</link>
      <description>Revision under section 263 was considered in relation to an assessee&#039;s claim for deduction under section 80G on CSR expenditure. The Tribunal noted that the allowability of such deduction was a highly debatable issue and had been supported by consistent Tribunal decisions, so it could not be treated as an erroneous and prejudicial assessment for revisional purposes. The absence of a specific enquiry by the Assessing Officer did not justify revision where the claim was legally tenable and further verification would serve no useful purpose. On that basis, the revisional jurisdiction under section 263 was held unsustainable and the revisionary order was set aside.</description>
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