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    <title>2025 (9) TMI 846 - ITAT MUMBAI</title>
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    <description>ITAT held that PCIT was justified in invoking revision under s.263 since the AO had not examined whether interest on delayed TDS was deductible or whether interest liability under s.201(1A)/s.206C(7) was payable; the matter is remitted to the AO for necessary inquiry and modification of the assessment. However, the challenge to the allowability of deduction under s.80G for CSR expenditure is considered highly debatable and outside s.263&#039;s scope, so that issue cannot be revised. Appeal by the assessee was partly allowed.</description>
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    <pubDate>Wed, 10 Sep 2025 00:00:00 +0530</pubDate>
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      <title>2025 (9) TMI 846 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=778357</link>
      <description>ITAT held that PCIT was justified in invoking revision under s.263 since the AO had not examined whether interest on delayed TDS was deductible or whether interest liability under s.201(1A)/s.206C(7) was payable; the matter is remitted to the AO for necessary inquiry and modification of the assessment. However, the challenge to the allowability of deduction under s.80G for CSR expenditure is considered highly debatable and outside s.263&#039;s scope, so that issue cannot be revised. Appeal by the assessee was partly allowed.</description>
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      <pubDate>Wed, 10 Sep 2025 00:00:00 +0530</pubDate>
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